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    <title>2024 (3) TMI 922 - CESTAT AHMEDABAD</title>
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    <description>Commission paid by a Special Economic Zone unit to foreign agents for export sales was stated to fall within the SEZ exemption framework, with section 26 of the SEZ Act treated as a substantive exemption for authorised operations and section 51 giving the SEZ Act overriding effect over inconsistent levy provisions and procedural conditions under the service tax notifications. On that basis, the service tax demand was said to be unsustainable. The text also states that the extended limitation period under section 73(1) of the Finance Act, 1994 could not be invoked because the payments were recorded in the books and routed through permitted foreign exchange channels, leaving no fraud, suppression, wilful misstatement, or intent to evade.</description>
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