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    <title>2026 (3) TMI 1636 - CESTAT NEW DELHI</title>
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    <description>Affiliation and renewal of affiliation by a university were treated as statutory functions under the governing education law, not as commercial activities performed for consideration. On that basis, the element of reciprocal contractual service and quid pro quo required for a taxable service was absent, so affiliation fees were not liable to service tax. Notification No. 25/2012 was also relied on as supporting the non-taxable character of the activity. The issue was stated to be covered by the cited High Court ruling, and no distinguishing facts were found, so the departmental appeal failed.</description>
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