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    <description>The appeal in the case was allowed to the extent of setting aside penalties imposed under section 78 of the Finance Act, 1994. However, the &#039;mark-up&#039; charged by the appellant for transactions with overseas merchant establishments was deemed taxable under section 65(105)(zm) and section 65(105)(zzzw) of the Finance Act, 1994. The service was not considered exported as the transactions were found to have taken place within India, with billing and payment in domestic currency.</description>
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      <description>The appeal in the case was allowed to the extent of setting aside penalties imposed under section 78 of the Finance Act, 1994. However, the &#039;mark-up&#039; charged by the appellant for transactions with overseas merchant establishments was deemed taxable under section 65(105)(zm) and section 65(105)(zzzw) of the Finance Act, 1994. The service was not considered exported as the transactions were found to have taken place within India, with billing and payment in domestic currency.</description>
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