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    <title>2026 (11) TMI 316 - CESTAT NEW DELHI</title>
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    <description>Engineering services involving construction design, quantities and costs fall under consulting engineer services when competing descriptions are equally specific, the essential-character test does not apply and that category appears first in the statutory order. Services provided to a recipient outside India qualified as exports without service tax. Before 14 May 2015, reimbursable expenses could not be included in taxable value under Rule 5, which was held ultra vires to that extent; Section 67 was subsequently amended. A debtors reconciliation that includes service tax in billings but omits corresponding tax receipts does not establish additional consideration; Revenue bears the burden of proof. Extended limitation requires an established statutory ground: incorrect self-assessment or non-payment alone does not establish wilful suppression or intent to evade, particularly where returns were filed and information was available in records.</description>
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