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    <title>2026 (5) TMI 1445 - CESTAT NEW DELHI</title>
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    <description>Reimbursable expenditure could not be added to the taxable value for reverse-charge service tax on legal, professional and GTA services for the relevant period, because the valuation basis relied on was not yet applicable; the demand on that component was therefore unsustainable. Where common input services were used for both taxable franchise service and exempted trading activity, full CENVAT credit was not admissible in the absence of proper separate accounts, and proportionate reversal was required. Deliberate failure to segregate credit attributable to exempted activity was treated as suppression of material facts, supporting invocation of the extended limitation period and consequential penalties.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792243</link>
      <description>Reimbursable expenditure could not be added to the taxable value for reverse-charge service tax on legal, professional and GTA services for the relevant period, because the valuation basis relied on was not yet applicable; the demand on that component was therefore unsustainable. Where common input services were used for both taxable franchise service and exempted trading activity, full CENVAT credit was not admissible in the absence of proper separate accounts, and proportionate reversal was required. Deliberate failure to segregate credit attributable to exempted activity was treated as suppression of material facts, supporting invocation of the extended limitation period and consequential penalties.</description>
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