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    <title>2025 (9) TMI 751 - CESTAT HYDERABAD</title>
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    <description>CESTAT remanded the matter to the Adjudicating Authority for fresh consideration, holding that the place of provision of services must be determined under the POPS Rules before treating services as export. The Tribunal observed Rule 3, not Rule 4, applies where the recipient is located outside India, but remanded because the record is unclear whether materials were physically made available by the service recipient (which would invoke Rule 4). The appeal was allowed insofar as factual re-examination is required to decide applicability of Rule 4 and consequent export/cum-tax benefits.</description>
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      <title>2025 (9) TMI 751 - CESTAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=778262</link>
      <description>CESTAT remanded the matter to the Adjudicating Authority for fresh consideration, holding that the place of provision of services must be determined under the POPS Rules before treating services as export. The Tribunal observed Rule 3, not Rule 4, applies where the recipient is located outside India, but remanded because the record is unclear whether materials were physically made available by the service recipient (which would invoke Rule 4). The appeal was allowed insofar as factual re-examination is required to decide applicability of Rule 4 and consequent export/cum-tax benefits.</description>
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      <pubDate>Mon, 08 Sep 2025 00:00:00 +0530</pubDate>
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