https://www.taxtmi.com/caselaws?id=774494 CESTAT Allahabad held that service tax demand based solely on income tax returns without identifying specific taxable services was invalid. The appellant provided software development services to overseas clients paid in foreign currency. Under Rule 3 of POPS Rules, place of provision was recipient's location outside India, qualifying services as exports not liable to service tax. Revenue failed to establish taxable event or identify specific services rendered. The show cause notice lacked clarity on nature of taxable service. Demand cannot be raised merely on income tax return discrepancies without examining reasons for mismatch or whether amounts represented consideration for taxable services. Appeal allowed, impugned order set aside. en-us Tue, 08 Jul 2025 00:00:00 +0530 Thu, 10 Jul 2025 08:39:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774494 CESTAT Allahabad held that service tax demand based solely on income tax returns without identifying specific taxable services was invalid. The appellant provided software development services to overseas clients paid in foreign currency. Under Rule 3 of POPS Rules, place of provision was recipient's location outside India, qualifying services as exports not liable to service tax. Revenue failed to establish taxable event or identify specific services rendered. The show cause notice lacked clarity on nature of taxable service. Demand cannot be raised merely on income tax return discrepancies without examining reasons for mismatch or whether amounts represented consideration for taxable services. Appeal allowed, impugned order set aside. Case-Laws Service Tax Tue, 08 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774494