Corporate guarantees without consideration do not attract service tax merely through imputed bank-guarantee charges.

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....Service tax on corporate guarantees arises only where consideration is received for rendering a taxable service. Corporate guarantees extended to associated enterprises without commission, fee or other consideration do not create taxable value merely because a notional amount can be computed using prevailing bank-guarantee rates. A precedent involving a corporate guarantee issued for paid consideration does not apply where the guarantee was provided without consideration. The demand for service tax on such guarantees was therefore dropped, and the Revenue's appeal was dismissed.....