https://www.taxtmi.com/caselaws?id=783771 Amounts received as upfront fee and excess spread income on sell-down of future receivables were held to be consideration from sale of receivables (profit/interest component) and not consideration for any "service" under the Finance Act, 1994; applying the activity-based concept of service tax and binding departmental circulars, service tax demand on these amounts was unsustainable, rendering the Revenue's challenge to dropping of demand untenable. Allegations of suppression to invoke the extended limitation were rejected because earlier SCNs on the same facts showed departmental knowledge, barring extended period for later SCNs; consequently, extended period demands failed. For collection efficiency fee and sell-down servicing fee, tax liability was not disputed and interest on delayed payment was upheld; the Revenue appeal was dismissed. en-us Thu, 18 Dec 2025 00:00:00 +0530 Sat, 20 Dec 2025 13:15:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783771 Amounts received as upfront fee and excess spread income on sell-down of future receivables were held to be consideration from sale of receivables (profit/interest component) and not consideration for any "service" under the Finance Act, 1994; applying the activity-based concept of service tax and binding departmental circulars, service tax demand on these amounts was unsustainable, rendering the Revenue's challenge to dropping of demand untenable. Allegations of suppression to invoke the extended limitation were rejected because earlier SCNs on the same facts showed departmental knowledge, barring extended period for later SCNs; consequently, extended period demands failed. For collection efficiency fee and sell-down servicing fee, tax liability was not disputed and interest on delayed payment was upheld; the Revenue appeal was dismissed. Case-Laws Service Tax Thu, 18 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783771