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    <title>2025 (6) TMI 1598 - CESTAT CHANDIGARH</title>
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    <description>Commission paid to overseas agents for procuring export orders and related work was held outside the Indian service tax net under reverse charge because the services were found to have been rendered and received entirely outside India; the statutory deeming provisions did not apply where receipt in India was absent, so the demand failed on merits. The extended period of limitation was also unavailable because the levy was treated as fully CENVATable, prior departmental awareness of the activity negated suppression, and the later notice was only a fresh attempt to tax the same services. The demand and penalties were therefore set aside.</description>
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      <description>Commission paid to overseas agents for procuring export orders and related work was held outside the Indian service tax net under reverse charge because the services were found to have been rendered and received entirely outside India; the statutory deeming provisions did not apply where receipt in India was absent, so the demand failed on merits. The extended period of limitation was also unavailable because the levy was treated as fully CENVATable, prior departmental awareness of the activity negated suppression, and the later notice was only a fresh attempt to tax the same services. The demand and penalties were therefore set aside.</description>
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