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CESTAT held that intermediary services related to goods became taxable from 01.10.2014 following amendments to POPS Rules, 2012. Design and development services were determined to be export of services as the place of provision was located outside India, with no third-party involvement. Given voluntary tax registration, service tax compliance, and absence of fraudulent intent, the tribunal found no grounds for extended limitation period. The demand for service tax was consequently set aside, favoring the appellant's position on service classification and tax treatment.