Reverse Tax Levy u/s 66A Only Applies to Taxable Services; Royalty Demand Unjustified Without Valid Tax Basis.

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....The question of a reverse levy of tax on the recipient of the service under section 66A of the Finance Act, 1994 would arise only if the service itself is taxable and, in the absence of any reason to subject the said royalty to tax, the demand under section 66A would not survive.....