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of Overseas service providers provided data collection services to the respondent. The activities were merely data collection through questionnaires, with no research or interpretation. The raw data was supplied back to the respondent for further analysis. These services cannot be classified as 'Market Research Services' as there was no research involved. The services were akin to an architect outsourcing land surveying, which is an input but not architectural services itself. Similarly, a tour operator hiring buses does not make it a bus service. The classification as 'Online Information and Database Access or Retrieval Services' is irrelevant. The demand to classify data collection as market research cannot be sustained. Additionally, the extended period of limitation for issuing the show cause notice cannot be invoked as there was no mala fide intent or evasion. Any service tax payable would have been available as CENVAT credit, making it revenue neutral. The revenue appeal was dismissed by the CESTAT.
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