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CESTAT allowed the appeal, ruling that Appellant's support services to Malaysian entity constituted export of services under Finance Act 1994. The Tribunal found that payment in foreign currency was adequately evidenced through invoice copies, and under Place of Provision of Service Rules 2012, service location was Malaysia as the recipient's place, not India. The demand under manpower recruitment services was unsustainable as merely providing qualified staff lists did not constitute recruitment services. Additionally, the service tax demand for renting immovable property was unjustified since Appellant was already paying service tax for such services during the relevant period. The Tribunal set aside the entire service tax demand.
CESTAT allowed the appeal, ruling that Appellant's support services to Malaysian entity constituted export of services under Finance Act 1994. The Tribunal found that payment in foreign currency was adequately evidenced through invoice copies, and under Place of Provision of Service Rules 2012, service location was Malaysia as the recipient's place, not India. The demand under manpower recruitment services was unsustainable as merely providing qualified staff lists did not constitute recruitment services. Additionally, the service tax demand for renting immovable property was unjustified since Appellant was already paying service tax for such services during the relevant period. The Tribunal set aside the entire service tax demand.
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