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    <title>2025 (1) TMI 345 - CESTAT ALLAHABAD</title>
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    <description>CESTAT Allahabad held that services provided by appellant to foreign entity constituted export of services not liable to service tax. Tribunal applied Rule 3 of Place of Provision of Services Rules, determining service location as Canada where recipient was located, not India where services were performed. Rule 4(b) was deemed inapplicable as no contract existed between foreign entity and Indian farmers. Court distinguished between service recipient (foreign exporter) and end beneficiaries (farmers), emphasizing that obligation to pay and consumption location determine taxability. Additionally, discounts provided were classified as price reductions for goods sale, not taxable services. Appeal was allowed and demand confirmation set aside.</description>
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    <pubDate>Mon, 06 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 345 - CESTAT ALLAHABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=764283</link>
      <description>CESTAT Allahabad held that services provided by appellant to foreign entity constituted export of services not liable to service tax. Tribunal applied Rule 3 of Place of Provision of Services Rules, determining service location as Canada where recipient was located, not India where services were performed. Rule 4(b) was deemed inapplicable as no contract existed between foreign entity and Indian farmers. Court distinguished between service recipient (foreign exporter) and end beneficiaries (farmers), emphasizing that obligation to pay and consumption location determine taxability. Additionally, discounts provided were classified as price reductions for goods sale, not taxable services. Appeal was allowed and demand confirmation set aside.</description>
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