https://www.taxtmi.com/caselaws?id=795477 Reimbursement of statutory apprentice stipends was not consideration for commercial training and coaching service where the Board reimbursed half the stipend without any mark-up. Taxability under the Finance Act, 1994 requires a service-provider and service-recipient relationship and commercial quid pro quo. The reimbursement was characterised as a welfare grant, with the appellant acting at most as a pure agent transmitting stipend amounts rather than providing a service to the Board. For the period before 14 May 2015, Section 67 did not allow expenditure or costs to be included in taxable value unless they constituted consideration for the service. The service-tax demand, interest and penalty were therefore unsustainable. en-us Tue, 21 Jul 2026 00:00:00 +0530 Thu, 23 Jul 2026 08:42:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795477 Reimbursement of statutory apprentice stipends was not consideration for commercial training and coaching service where the Board reimbursed half the stipend without any mark-up. Taxability under the Finance Act, 1994 requires a service-provider and service-recipient relationship and commercial quid pro quo. The reimbursement was characterised as a welfare grant, with the appellant acting at most as a pure agent transmitting stipend amounts rather than providing a service to the Board. For the period before 14 May 2015, Section 67 did not allow expenditure or costs to be included in taxable value unless they constituted consideration for the service. The service-tax demand, interest and penalty were therefore unsustainable. Case-Laws Service Tax Tue, 21 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795477