https://www.taxtmi.com/caselaws?id=798161 Pre-01.07.2012 service-tax demands under the positive-list regime required the show cause notice to identify the specific taxable service under Section 65(105) of the Finance Act, 1994. Foreign-currency expenditure and reverse-charge non-payment alone could not establish liability across heterogeneous transactions. An appellate authority could not introduce new classifications, such as Commercial Training or Coaching Service or Club or Association Service, to cure that foundational omission. Accordingly, the restored demand lacked a valid notice-based basis; consequential interest and Section 78 penalty also failed. Separately adjudicated post-01.07.2012 proceedings remained outside the scope of reopening and retained their existing effect. en-us Mon, 31 Aug 2026 00:00:00 +0530 Thu, 03 Sep 2026 08:20:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798161 Pre-01.07.2012 service-tax demands under the positive-list regime required the show cause notice to identify the specific taxable service under Section 65(105) of the Finance Act, 1994. Foreign-currency expenditure and reverse-charge non-payment alone could not establish liability across heterogeneous transactions. An appellate authority could not introduce new classifications, such as Commercial Training or Coaching Service or Club or Association Service, to cure that foundational omission. Accordingly, the restored demand lacked a valid notice-based basis; consequential interest and Section 78 penalty also failed. Separately adjudicated post-01.07.2012 proceedings remained outside the scope of reopening and retained their existing effect. Case-Laws Service Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798161