https://www.taxtmi.com/caselaws?id=799817 Reverse-charge service tax on foreign services cannot be sustained merely by applying the default place-of-provision rule where the taxpayer invoked specific place-of-provision rules and Revenue did not establish their inapplicability. Revenue bears the burden of proving taxability, and the extended period is unavailable where returns, audit records, and supporting documents disclose the relevant facts. Demurrage for cargo-loading or discharge delays is a penal charge, liquidated damages, or penal rent rather than consideration for a service, and falls outside the service-tax levy. No service-tax liability survives under the show-cause notice. en-us Fri, 25 Sep 2026 00:00:00 +0530 Mon, 28 Sep 2026 08:12:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799817 Reverse-charge service tax on foreign services cannot be sustained merely by applying the default place-of-provision rule where the taxpayer invoked specific place-of-provision rules and Revenue did not establish their inapplicability. Revenue bears the burden of proving taxability, and the extended period is unavailable where returns, audit records, and supporting documents disclose the relevant facts. Demurrage for cargo-loading or discharge delays is a penal charge, liquidated damages, or penal rent rather than consideration for a service, and falls outside the service-tax levy. No service-tax liability survives under the show-cause notice. Case-Laws Service Tax Fri, 25 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799817