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    <title>2022 (7) TMI 91 - CESTAT MUMBAI</title>
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    <description>A seafarers recruitment and crew management service was held not to be intermediary service because the provider independently selected, trained and supplied crew on a principal-to-principal basis to an overseas client, rather than arranging or facilitating a supply between two other persons. On that reasoning, the place-of-provision rule invoked by the department did not prevent export treatment, and the refund claim of accumulated CENVAT credit under the refund notification remained maintainable. The rejection of refund, including the appellate confirmation, was set aside and refund with applicable interest was directed.</description>
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      <description>A seafarers recruitment and crew management service was held not to be intermediary service because the provider independently selected, trained and supplied crew on a principal-to-principal basis to an overseas client, rather than arranging or facilitating a supply between two other persons. On that reasoning, the place-of-provision rule invoked by the department did not prevent export treatment, and the refund claim of accumulated CENVAT credit under the refund notification remained maintainable. The rejection of refund, including the appellate confirmation, was set aside and refund with applicable interest was directed.</description>
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