https://www.taxtmi.com/caselaws?id=792799 Letting out specified railway space for hoardings and billboards does not constitute support services where the railway is not outsourcing any advertising or promotional function to the allottee; on that basis, reverse charge service tax is not attracted. The arrangement is properly characterised as renting of immovable property because the contracts only permit use of demarcated space for consideration described as licence fee. Non-declaration of such licence fee in ST-3 returns does not by itself establish suppression when there is no statutory obligation to disclose services not covered by reverse charge, so extended limitation and penalties under Sections 76, 77 and 78 are not sustainable. en-us Wed, 03 Jun 2026 00:00:00 +0530 Thu, 04 Jun 2026 08:37:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792799 Letting out specified railway space for hoardings and billboards does not constitute support services where the railway is not outsourcing any advertising or promotional function to the allottee; on that basis, reverse charge service tax is not attracted. The arrangement is properly characterised as renting of immovable property because the contracts only permit use of demarcated space for consideration described as licence fee. Non-declaration of such licence fee in ST-3 returns does not by itself establish suppression when there is no statutory obligation to disclose services not covered by reverse charge, so extended limitation and penalties under Sections 76, 77 and 78 are not sustainable. Case-Laws Service Tax Wed, 03 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792799