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CESTAT allowed the appeal by way of remand, holding that the impugned demand of service tax under the reverse charge mechanism on the entire reimbursed overseas office expenses, purportedly as consideration for business support services, is untenable except insofar as amounts conceded by the Appellant. The Tribunal treated the Appellant's foreign offices as separate persons under section 66A for analytic purposes but declined to sustain valuation under Rule 5(1) of the Service Tax (Determination of Value) Rules 2006 for the full reimbursed amounts. The Tribunal also rejected the Respondent's plea for remand solely to verify the stated purpose and actuality of payments, finding no merit in that submission.
CESTAT allowed the appeal by way of remand, holding that the impugned demand of service tax under the reverse charge mechanism on the entire reimbursed overseas office expenses, purportedly as consideration for business support services, is untenable except insofar as amounts conceded by the Appellant. The Tribunal treated the Appellant's foreign offices as separate persons under section 66A for analytic purposes but declined to sustain valuation under Rule 5(1) of the Service Tax (Determination of Value) Rules 2006 for the full reimbursed amounts. The Tribunal also rejected the Respondent's plea for remand solely to verify the stated purpose and actuality of payments, finding no merit in that submission.
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