https://www.taxtmi.com/caselaws?id=783464 CESTAT Chennai allowed the appeal substantially, holding that payments made by the appellant to its foreign subsidiaries/licensees did not constitute "consideration" for any taxable service under Section 65B(44) and, hence, no service tax was payable under RCM. It found the impugned arrangements to be revenue-sharing/price adjustments, with services performed entirely outside the taxable territory, rendering the demands under Sections 66B and POPS Rules unsustainable. The Tribunal also held that extended limitation and penalties under Sections 77 and 78 were not invocable, given revenue-neutrality and absence of suppression or intent to evade. The demand of Rs. 36.77 crore was set aside, while the limited demand of Rs. 1.16 crore was remanded for verification of tax payment. en-us Mon, 15 Dec 2025 00:00:00 +0530 Wed, 17 Dec 2025 08:28:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783464 CESTAT Chennai allowed the appeal substantially, holding that payments made by the appellant to its foreign subsidiaries/licensees did not constitute "consideration" for any taxable service under Section 65B(44) and, hence, no service tax was payable under RCM. It found the impugned arrangements to be revenue-sharing/price adjustments, with services performed entirely outside the taxable territory, rendering the demands under Sections 66B and POPS Rules unsustainable. The Tribunal also held that extended limitation and penalties under Sections 77 and 78 were not invocable, given revenue-neutrality and absence of suppression or intent to evade. The demand of Rs. 36.77 crore was set aside, while the limited demand of Rs. 1.16 crore was remanded for verification of tax payment. Case-Laws Service Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783464