https://www.taxtmi.com/caselaws?id=796457 Service tax on mining royalty depends on when the right to use natural resources was provided or agreed to be provided. Where mining rights were allotted before their exclusion from the negative list, subsequent execution of a lease deed or payment of royalty after 1 April 2016 does not make the earlier assignment taxable; the Point of Taxation Rules cannot expand the charging provision. Extended limitation is unavailable where taxability was a bona fide interpretational dispute, relevant transactions were disclosed in statutory records, and there was no suppression, fraud, wilful misstatement or intent to evade tax. The demand, consequential interest and penalties were therefore unsustainable. en-us Tue, 04 Aug 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796457 Service tax on mining royalty depends on when the right to use natural resources was provided or agreed to be provided. Where mining rights were allotted before their exclusion from the negative list, subsequent execution of a lease deed or payment of royalty after 1 April 2016 does not make the earlier assignment taxable; the Point of Taxation Rules cannot expand the charging provision. Extended limitation is unavailable where taxability was a bona fide interpretational dispute, relevant transactions were disclosed in statutory records, and there was no suppression, fraud, wilful misstatement or intent to evade tax. The demand, consequential interest and penalties were therefore unsustainable. Case-Laws Service Tax Tue, 04 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796457