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of Export of service or not - Since because the ultimate beneficiary is abroad, it cannot be claimed that the appellants are exporting services. Neither the place of rendering of the activity nor the type of service rendered by the appellants nor the recipient of such service are stationed abroad. Therefore, we are not inclined to consider such service as an export of service - the demand of service tax on the money transfer service rendered by the appellants requires to be upheld. - AT
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