https://www.taxtmi.com/caselaws?id=248722 The CESTAT held that the Indian entity of the appellant is not liable to pay service tax under reverse charge for services received from a foreign CRS provider, as the contract and consumption of services occurred outside India with the foreign head office. The Indian entity merely acts as an agent and does not directly receive or use the service. The demand raised under extended limitation was barred under Section 11A, given the bona fide belief that no tax was payable and the revenue-neutral nature of the transaction, since any tax paid would have been creditable against admitted liabilities. Consequently, the demand and penalty were set aside in favor of the appellant. en-us Fri, 23 May 2014 00:00:00 +0530 Mon, 28 Jul 2025 18:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248722 The CESTAT held that the Indian entity of the appellant is not liable to pay service tax under reverse charge for services received from a foreign CRS provider, as the contract and consumption of services occurred outside India with the foreign head office. The Indian entity merely acts as an agent and does not directly receive or use the service. The demand raised under extended limitation was barred under Section 11A, given the bona fide belief that no tax was payable and the revenue-neutral nature of the transaction, since any tax paid would have been creditable against admitted liabilities. Consequently, the demand and penalty were set aside in favor of the appellant. Case-Laws Service Tax Fri, 23 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248722