Fees from securitizing and selling down future receivables: upfront/excess spread not a service, tax demand dropped; appeal dismissed

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....Upfront fee and excess spread income arising from securitization/sell-down of future receivables were held to be profits/interest from sale of receivables, with no underlying "service" element, and therefore not exigible to service tax under Business Support Service; the Department's challenge to dropping of these demands was not maintainable. Collection efficiency fee and sell-down servicing fee were accepted as taxable, and interest on delayed payment was upheld; however, this did not sustain the Revenue's appeal on merits. Alleged suppression was rejected since the material facts were already within departmental knowledge from an earlier notice, making invocation of the extended limitation period unjustified. Revenue's appeal was dismissed. - CESTAT....