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    <title>2026 (4) TMI 947 - CESTAT NEW DELHI</title>
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    <description>Licence fee paid to Indian Railways for permission to operate food stalls and onboard catering was not consideration for a taxable support service, because the arrangement was only a permission to carry on catering activity and did not create a taxable service-provider relationship. On that basis, service tax under reverse charge mechanism was not payable and the demand failed. The extended limitation period was also unjustified, as no intent to evade tax could be attributed once the underlying activity was held non-taxable; the demand for the period prior to 25.10.2015 was therefore time barred. The impugned demand was set aside in full.</description>
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    <pubDate>Mon, 23 Mar 2026 00:00:00 +0530</pubDate>
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      <title>2026 (4) TMI 947 - CESTAT NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=789878</link>
      <description>Licence fee paid to Indian Railways for permission to operate food stalls and onboard catering was not consideration for a taxable support service, because the arrangement was only a permission to carry on catering activity and did not create a taxable service-provider relationship. On that basis, service tax under reverse charge mechanism was not payable and the demand failed. The extended limitation period was also unjustified, as no intent to evade tax could be attributed once the underlying activity was held non-taxable; the demand for the period prior to 25.10.2015 was therefore time barred. The impugned demand was set aside in full.</description>
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      <pubDate>Mon, 23 Mar 2026 00:00:00 +0530</pubDate>
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