https://www.taxtmi.com/caselaws?id=793572 A revenue-sharing receipt under a railway participative investment arrangement was treated as return on investment, not consideration for Business Support Service, because the appellant financed and built the infrastructure while the railways operated the line and shared freight revenue. The required service provider-service recipient relationship and quid pro quo were absent, so the demand on merits failed. The assessee's belief was held bona fide, with no suppression to evade tax, making the extended period of limitation and penalties unsustainable. The demand and consequential penalties therefore could not be sustained. en-us Tue, 16 Jun 2026 00:00:00 +0530 Fri, 19 Jun 2026 08:24:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793572 A revenue-sharing receipt under a railway participative investment arrangement was treated as return on investment, not consideration for Business Support Service, because the appellant financed and built the infrastructure while the railways operated the line and shared freight revenue. The required service provider-service recipient relationship and quid pro quo were absent, so the demand on merits failed. The assessee's belief was held bona fide, with no suppression to evade tax, making the extended period of limitation and penalties unsustainable. The demand and consequential penalties therefore could not be sustained. Case-Laws Service Tax Tue, 16 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793572