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CESTAT allowed appellant's appeal, overturning the Commissioner(Appeals) order. The tribunal determined that the services rendered to an overseas company did not constitute an 'intermediary service' based on the clarificatory circular. The tribunal rejected the earlier interpretation that the services fell under Rule 9(c) of POPS Rules, 2012, thus not classifying them as non-export services. Consequently, the refund claims were reinstated, and the original orders rejecting the refund were set aside. The decision provides significant clarification on the classification of intermediary services and export of services under tax regulations.
CESTAT allowed appellant's appeal, overturning the Commissioner(Appeals) order. The tribunal determined that the services rendered to an overseas company did not constitute an 'intermediary service' based on the clarificatory circular. The tribunal rejected the earlier interpretation that the services fell under Rule 9(c) of POPS Rules, 2012, thus not classifying them as non-export services. Consequently, the refund claims were reinstated, and the original orders rejecting the refund were set aside. The decision provides significant clarification on the classification of intermediary services and export of services under tax regulations.
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