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    <title>2026 (5) TMI 133 - CESTAT MUMBAI</title>
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    <description>Activities undertaken under a project development agreement between co-venturers were treated as part of a joint venture for a common commercial objective, not as a taxable service. Each co-venturer&#039;s obligations were discharged in its own interest and as capital contribution to the venture, so no distinct service-provider and service-recipient relationship existed. In the absence of proof that the money flow was consideration for a taxable activity, service tax could not be demanded. Once the underlying activity was found non-taxable, the valuation demand also failed. The service tax demands were therefore unsustainable and were set aside.</description>
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