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    <title>2026 (6) TMI 178 - CESTAT CHENNAI</title>
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    <description>Leasing of tea estates for plantation operations was treated as an agricultural arrangement, not taxable renting of immovable property, because the land, buildings, labour quarters and machinery were integral to cultivation, irrigation, harvesting and processing of green tea leaves. The consideration was linked to agricultural output, and the pre-negative list exemption for services relating to agriculture, as well as the post-01.07.2012 exclusion under Section 66D, applied. Payment of wages and deployment of workers did not amount to manpower recruitment or supply agency service, and provision of tractors and related facilities did not constitute supply of tangible goods service, as no separate consideration or transfer of effective control was shown.</description>
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