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    <title>2025 (1) TMI 76 - CESTAT AHMEDABAD</title>
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    <description>Cross-border services rendered to foreign group companies were examined to determine whether the recipients were the appellant&#039;s own establishment or separate legal entities. The analysis turned on the distinction drawn in the explanation to section 65B(44) of the Finance Act, 1994, and on whether the foreign companies were independently incorporated and registered abroad. The record suggested distinct legal entities, and earlier decisions on identical facts were said to support the appellant&#039;s case. As the impugned order did not properly address that legal relationship or the cited precedent, the finding that the services were not export of service could not be sustained on the existing adjudication and the matter required reconsideration.</description>
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    <pubDate>Wed, 04 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 76 - CESTAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=764014</link>
      <description>Cross-border services rendered to foreign group companies were examined to determine whether the recipients were the appellant&#039;s own establishment or separate legal entities. The analysis turned on the distinction drawn in the explanation to section 65B(44) of the Finance Act, 1994, and on whether the foreign companies were independently incorporated and registered abroad. The record suggested distinct legal entities, and earlier decisions on identical facts were said to support the appellant&#039;s case. As the impugned order did not properly address that legal relationship or the cited precedent, the finding that the services were not export of service could not be sustained on the existing adjudication and the matter required reconsideration.</description>
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      <pubDate>Wed, 04 Dec 2024 00:00:00 +0530</pubDate>
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