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    <title>2024 (12) TMI 1194 - CESTAT NEW DELHI</title>
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    <description>CESTAT New Delhi held that appellant&#039;s services to overseas universities constituted export of services rather than intermediary services as alleged by the department. The tribunal found that agreements explicitly denied agent-principal relationship with foreign universities, services were rendered for promotion of foreign universities among Indian students, and payments were received in foreign exchange from universities, not from students. Since service recipients were located outside taxable territory, the place of provision was outside India, making services exempt from service tax. The tribunal ruled that Rule 9 of Place of Provision Rules was wrongly invoked, extended limitation period was inapplicable as appellant regularly filed returns and paid applicable taxes, and the show cause notice was time-barred. Appeal allowed.</description>
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    <pubDate>Fri, 13 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2024 (12) TMI 1194 - CESTAT NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=763614</link>
      <description>CESTAT New Delhi held that appellant&#039;s services to overseas universities constituted export of services rather than intermediary services as alleged by the department. The tribunal found that agreements explicitly denied agent-principal relationship with foreign universities, services were rendered for promotion of foreign universities among Indian students, and payments were received in foreign exchange from universities, not from students. Since service recipients were located outside taxable territory, the place of provision was outside India, making services exempt from service tax. The tribunal ruled that Rule 9 of Place of Provision Rules was wrongly invoked, extended limitation period was inapplicable as appellant regularly filed returns and paid applicable taxes, and the show cause notice was time-barred. Appeal allowed.</description>
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      <pubDate>Fri, 13 Dec 2024 00:00:00 +0530</pubDate>
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