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    <title>2025 (12) TMI 1865 - CESTAT NEW DELHI</title>
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    <description>Service tax under reverse charge on royalty paid to Government for a mining lease turned on whether the service was provided or agreed to be provided before 01.04.2016. Before that date, Government services were largely within the negative list, while the 01.04.2016 amendment moved services by Government to business entities outside it. Because the lease was stated to have been executed before 01.04.2016, the lease documents had to be examined to determine the correct tax position. The demand could not be finally sustained on the existing record, and the matter was remanded for fresh decision under the pre-01.04.2016 law.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469695</link>
      <description>Service tax under reverse charge on royalty paid to Government for a mining lease turned on whether the service was provided or agreed to be provided before 01.04.2016. Before that date, Government services were largely within the negative list, while the 01.04.2016 amendment moved services by Government to business entities outside it. Because the lease was stated to have been executed before 01.04.2016, the lease documents had to be examined to determine the correct tax position. The demand could not be finally sustained on the existing record, and the matter was remanded for fresh decision under the pre-01.04.2016 law.</description>
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