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of Classification of service provided by company - Not Chartered Accountant Services or Market Research Agency's Services - Nature of services rendered includes consultancy, advice, assistance in mergers & acquisitions, due diligence, financial viability evaluation, classifiable under Management or Business Consultants Services. Services cannot be classified under Chartered Accountant Services as company is not engaged in practice of chartered accountancy or permitted by Institute of Chartered Accountants of India. Export of service - Services provided to PwC Overseas Network Firms, not directly to clients, qualify as export of services under Export of Services Rules, 2005 with consideration received in convertible foreign exchange. Time Limitation - Extended period of limitation not invocable as dispute involves interpretation of statutory provisions, no fraud or willful misstatement established. Interest and penalty - Not payable as demand of service tax itself unsustainable. Impugned order set aside, appeal allowed.
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