https://www.taxtmi.com/caselaws?id=784634 A payment made under a memorandum of understanding for upgradation and modernisation of a sugar mill was held not to be consideration for renting of immovable property, because the separate lease deed covered only nominal rent for the land and the disputed amount was linked to machinery improvement, capacity enhancement and energy efficiency. The arrangement was treated as a joint venture that never materialised into a service transaction, so no service element was found between the parties. On these facts, service tax under renting of immovable property was unsustainable and the departmental circular was inapplicable. en-us Wed, 07 Jan 2026 00:00:00 +0530 Fri, 09 Jan 2026 08:29:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784634 A payment made under a memorandum of understanding for upgradation and modernisation of a sugar mill was held not to be consideration for renting of immovable property, because the separate lease deed covered only nominal rent for the land and the disputed amount was linked to machinery improvement, capacity enhancement and energy efficiency. The arrangement was treated as a joint venture that never materialised into a service transaction, so no service element was found between the parties. On these facts, service tax under renting of immovable property was unsustainable and the departmental circular was inapplicable. Case-Laws Service Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784634