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    <description>Reimbursement of common expenses under a cost-sharing arrangement with a wholly owned subsidiary was treated as a pass-through of actual third-party costs, with no identifiable service rendered to the subsidiary; it was therefore not taxable as Business Support Service for the relevant period. The broadened post-2011 definition of support services was held prospective and inapplicable to the pre-amendment period. On that basis, the receipts were characterised as reimbursement rather than consideration for service, and the demand was also viewed as revenue neutral. Penalty could not survive where no service tax was payable.</description>
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