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    <title>2026 (1) TMI 326 - CESTAT NEW DELHI</title>
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    <description>Training imparted by the appellant to existing construction workers under an arrangement with a government-recognized testing/certification agency was held to be taxable as &quot;commercial training or coaching&quot; because it was skill upgradation by an institute and did not culminate in a qualification recognized by law; exemption under the Notifications dated 20.06.2003 and 29.04.2010 was denied for non-fulfilment of stipulated conditions, including lack of specified courses and requisite registration/association status, resulting in confirmation of service tax. Consultancy amounts received from the intermediary agency were held taxable in the appellant&#039;s hands despite tax collection from the end-client, so the demand was upheld. Renting receipts were held taxable irrespective of ownership, so tax liability was sustained. Interest under s.75 was upheld, but penalties under ss.77 and 78 were set aside for lack of reasons and benefit of s.80; appeals were partly allowed.</description>
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    <pubDate>Wed, 07 Jan 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=784570</link>
      <description>Training imparted by the appellant to existing construction workers under an arrangement with a government-recognized testing/certification agency was held to be taxable as &quot;commercial training or coaching&quot; because it was skill upgradation by an institute and did not culminate in a qualification recognized by law; exemption under the Notifications dated 20.06.2003 and 29.04.2010 was denied for non-fulfilment of stipulated conditions, including lack of specified courses and requisite registration/association status, resulting in confirmation of service tax. Consultancy amounts received from the intermediary agency were held taxable in the appellant&#039;s hands despite tax collection from the end-client, so the demand was upheld. Renting receipts were held taxable irrespective of ownership, so tax liability was sustained. Interest under s.75 was upheld, but penalties under ss.77 and 78 were set aside for lack of reasons and benefit of s.80; appeals were partly allowed.</description>
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      <pubDate>Wed, 07 Jan 2026 00:00:00 +0530</pubDate>
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