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    <title>2025 (4) TMI 819 - CESTAT BANGALORE</title>
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    <description>Exemption under Notifications No. 18/2009-ST and 42/2012-ST could not be denied merely because CENVAT credit had been taken on GTA or other export-related services, as the no-credit condition was confined to the specified service claimed for exemption; the objection on that ground failed. A plea that foreign commission agent service was taxable as an intermediary service was rejected on the facts, while services used exclusively for SEZ authorised operations were protected by the SEZ legislation and the related demand could not stand without addressing that statutory exemption. The extended period of limitation was also unavailable because fraud, collusion, wilful misstatement, or suppression with intent to evade tax was not established.</description>
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      <description>Exemption under Notifications No. 18/2009-ST and 42/2012-ST could not be denied merely because CENVAT credit had been taken on GTA or other export-related services, as the no-credit condition was confined to the specified service claimed for exemption; the objection on that ground failed. A plea that foreign commission agent service was taxable as an intermediary service was rejected on the facts, while services used exclusively for SEZ authorised operations were protected by the SEZ legislation and the related demand could not stand without addressing that statutory exemption. The extended period of limitation was also unavailable because fraud, collusion, wilful misstatement, or suppression with intent to evade tax was not established.</description>
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