https://www.taxtmi.com/caselaws?id=794203 Group-company assistance provided for a subsidiary's credit rating process does not, by itself, constitute "support services of business or commerce" unless it amounts to a substantive outsourced business-support function or operational or administrative assistance within the statutory definition. The inclusive wording of the taxable entry is context-limited and does not extend to incidental benefits arising from group membership. On the stated facts, the activity was not taxable, so the related service tax demand and penalty were unsustainable. Where the Revenue adopted inconsistent positions in the notices, suppression or wilful evasion could not be established for invoking the extended limitation period. As the activity was not taxable as an exempted service, Rule 6(3) of the CENVAT Credit Rules, 2004 was not attracted. en-us Wed, 17 Jun 2026 00:00:00 +0530 Thu, 02 Jul 2026 08:07:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794203 Group-company assistance provided for a subsidiary's credit rating process does not, by itself, constitute "support services of business or commerce" unless it amounts to a substantive outsourced business-support function or operational or administrative assistance within the statutory definition. The inclusive wording of the taxable entry is context-limited and does not extend to incidental benefits arising from group membership. On the stated facts, the activity was not taxable, so the related service tax demand and penalty were unsustainable. Where the Revenue adopted inconsistent positions in the notices, suppression or wilful evasion could not be established for invoking the extended limitation period. As the activity was not taxable as an exempted service, Rule 6(3) of the CENVAT Credit Rules, 2004 was not attracted. Case-Laws Service Tax Wed, 17 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794203