https://www.taxtmi.com/caselaws?id=775574 An exclusive distributorship arrangement was treated as export of service because the appellant earned sales commission from a recipient located outside India and received payment in convertible foreign currency; the invoice nomenclature did not override the actual commercial arrangement, so service tax was not attracted. The demand also could not rest on a new objection regarding non-receipt of foreign currency because that ground was not part of the show cause notice or the original adjudication, and an authority cannot travel beyond the notice. The extended limitation period was likewise unavailable because the transactions were recorded in books and returns, with no proof of suppression, wilful misstatement, or intent to evade tax. en-us Tue, 15 Jul 2025 00:00:00 +0530 Mon, 28 Jul 2025 08:27:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775574 An exclusive distributorship arrangement was treated as export of service because the appellant earned sales commission from a recipient located outside India and received payment in convertible foreign currency; the invoice nomenclature did not override the actual commercial arrangement, so service tax was not attracted. The demand also could not rest on a new objection regarding non-receipt of foreign currency because that ground was not part of the show cause notice or the original adjudication, and an authority cannot travel beyond the notice. The extended limitation period was likewise unavailable because the transactions were recorded in books and returns, with no proof of suppression, wilful misstatement, or intent to evade tax. Case-Laws Service Tax Tue, 15 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775574