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    <title>2025 (6) TMI 1356 - CESTAT BANGALORE</title>
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    <description>CESTAT Bangalore set aside the impugned order and remanded the matter for fresh adjudication regarding service tax liability on technical testing and certification services. The tribunal held that demand prior to 18.04.2006 was unsustainable as Section 66A was enacted from that date. Where testing and certification were performed entirely outside India, no service tax liability arose. Reimbursement expenses of Rs.45,25,532 without service element were not taxable. Extended limitation period was not applicable given ambiguous taxability and department&#039;s prior knowledge. All penalties were set aside due to absence of evasion intent and bona fide belief regarding non-taxability.</description>
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    <pubDate>Wed, 04 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1356 - CESTAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=773243</link>
      <description>CESTAT Bangalore set aside the impugned order and remanded the matter for fresh adjudication regarding service tax liability on technical testing and certification services. The tribunal held that demand prior to 18.04.2006 was unsustainable as Section 66A was enacted from that date. Where testing and certification were performed entirely outside India, no service tax liability arose. Reimbursement expenses of Rs.45,25,532 without service element were not taxable. Extended limitation period was not applicable given ambiguous taxability and department&#039;s prior knowledge. All penalties were set aside due to absence of evasion intent and bona fide belief regarding non-taxability.</description>
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      <pubDate>Wed, 04 Jun 2025 00:00:00 +0530</pubDate>
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