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of Export of services - non-receipt of convertible foreign exchange - non-payment of service tax - The appellants have, in fact fulfilled the first condition of Export of Services Rules, 2005 by rendering the same fully at Nepal. Therefore, they can be said to have entertained bonafide belief that no Service Tax is payable. All the documentary evidence shows that they have declared all the transactions in their books of accounts, ST 3 Returns and Income Tax Returns. - Demand beyond the normal period of limitation set aside - AT
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