https://www.taxtmi.com/caselaws?id=758165 CESTAT Chandigarh held that appellant's referral services to Canadian bank and foreign universities constituted export of services, not intermediary services under Rule 2(f) of Place of Provision of Service Rules, 2012. The tribunal applied three-condition test from Punjab Haryana HC's Genpact India case requiring principal-agency relationship, facilitation role, and non-performance of main service. Following its own precedent in appellant's earlier case, tribunal ruled services qualified as export of services exempted from service tax. Extended limitation period invocation was deemed improper as department had knowledge of activities from previous proceedings. Interest and penalties were rejected as underlying service tax demand was unsustainable. Appeal allowed, impugned order set aside. en-us Fri, 06 Sep 2024 00:00:00 +0530 Sat, 07 Sep 2024 12:44:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758165 CESTAT Chandigarh held that appellant's referral services to Canadian bank and foreign universities constituted export of services, not intermediary services under Rule 2(f) of Place of Provision of Service Rules, 2012. The tribunal applied three-condition test from Punjab Haryana HC's Genpact India case requiring principal-agency relationship, facilitation role, and non-performance of main service. Following its own precedent in appellant's earlier case, tribunal ruled services qualified as export of services exempted from service tax. Extended limitation period invocation was deemed improper as department had knowledge of activities from previous proceedings. Interest and penalties were rejected as underlying service tax demand was unsustainable. Appeal allowed, impugned order set aside. Case-Laws Service Tax Fri, 06 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758165