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    <title>Fees from securitizing and selling down future receivables: upfront/excess spread not a service, tax demand dropped; appeal dismissed</title>
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    <description>Upfront fee and excess spread income arising from securitization/sell-down of future receivables were held to be profits/interest from sale of receivables, with no underlying &quot;service&quot; element, and therefore not exigible to service tax under Business Support Service; the Department&#039;s challenge to dropping of these demands was not maintainable. Collection efficiency fee and sell-down servicing fee were accepted as taxable, and interest on delayed payment was upheld; however, this did not sustain the Revenue&#039;s appeal on merits. Alleged suppression was rejected since the material facts were already within departmental knowledge from an earlier notice, making invocation of the extended limitation period unjustified. Revenue&#039;s appeal was dismissed. - CESTAT</description>
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    <pubDate>Tue, 23 Dec 2025 07:59:05 +0530</pubDate>
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      <title>Fees from securitizing and selling down future receivables: upfront/excess spread not a service, tax demand dropped; appeal dismissed</title>
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      <description>Upfront fee and excess spread income arising from securitization/sell-down of future receivables were held to be profits/interest from sale of receivables, with no underlying &quot;service&quot; element, and therefore not exigible to service tax under Business Support Service; the Department&#039;s challenge to dropping of these demands was not maintainable. Collection efficiency fee and sell-down servicing fee were accepted as taxable, and interest on delayed payment was upheld; however, this did not sustain the Revenue&#039;s appeal on merits. Alleged suppression was rejected since the material facts were already within departmental knowledge from an earlier notice, making invocation of the extended limitation period unjustified. Revenue&#039;s appeal was dismissed. - CESTAT</description>
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