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    <title>2026 (3) TMI 911 - CESTAT BANGALORE</title>
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    <description>Recorded software supplied on physical media is characterised as goods, not taxable as service; the service tax demand on CDs is set aside. Electronically supplied or licensed software imported under high-sea sales is treated as import of services under Section 66/66A and the Taxation of Services (Provided from outside India and received in India) Rules, 2006, and is taxable where the rendering/receipt occurs after the levy; demand for electronically downloaded software for the specified post 2008 period is confirmed. Services received before the taxable date remain non taxable despite later payments; extended limitation was held justified for confirmed demands.</description>
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      <description>Recorded software supplied on physical media is characterised as goods, not taxable as service; the service tax demand on CDs is set aside. Electronically supplied or licensed software imported under high-sea sales is treated as import of services under Section 66/66A and the Taxation of Services (Provided from outside India and received in India) Rules, 2006, and is taxable where the rendering/receipt occurs after the levy; demand for electronically downloaded software for the specified post 2008 period is confirmed. Services received before the taxable date remain non taxable despite later payments; extended limitation was held justified for confirmed demands.</description>
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