Tribunal Overturns Service Tax and Penalty on Revenue Sharing in Healthcare Services, Upholds Principal-to-Principal Model.

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....The case pertains to the levy of service tax, interest, and penalty on business support services involving revenue sharing between the appellant and diagnostic service providers (DSPs). The key points are: The agreements between the appellant and DSPs were principal-to-principal in nature for revenue sharing, not for rendering taxable services by the appellant. The appellant provided infrastructure, and DSPs installed equipment; revenue from patients was shared without any service charges paid by DSPs. The transactions were recognized as principal-to-principal by a circular, and providing basic amenities cannot be considered support services. Healthcare services were exempted from service tax during the relevant period. The appellant did no.........