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    <title>2018 (5) TMI 1417 - CESTAT CHANDIGARH</title>
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    <description>Business promotion and referral services rendered on the provider&#039;s own account to foreign clients were treated as non-intermediary services rather than intermediary services under Rule 2(f) of the Place of Provision of Services Rules, 2012, with Rule 3 applied to support export treatment and Rule 9 rejected on the facts. The discussion also notes that such referral services were not liable to service tax post 01.07.2012 where the provider was not merely arranging the main service between two other persons. On limitation and penalty, the analysis records that interpretative dispute alone did not establish suppression or wilful misstatement, so the extended period and penalty were not sustainable for the disputed referral services.</description>
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      <link>https://www.taxtmi.com/caselaws?id=360853</link>
      <description>Business promotion and referral services rendered on the provider&#039;s own account to foreign clients were treated as non-intermediary services rather than intermediary services under Rule 2(f) of the Place of Provision of Services Rules, 2012, with Rule 3 applied to support export treatment and Rule 9 rejected on the facts. The discussion also notes that such referral services were not liable to service tax post 01.07.2012 where the provider was not merely arranging the main service between two other persons. On limitation and penalty, the analysis records that interpretative dispute alone did not establish suppression or wilful misstatement, so the extended period and penalty were not sustainable for the disputed referral services.</description>
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