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    <title>2025 (10) TMI 680 - CESTAT CHENNAI</title>
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    <description>CESTAT CHENNAI - AT held that the overseas entities were the employers and their transfer of expatriates to the appellant constituted supply of manpower services. The Tribunal declined invocation of the extended limitation period, finding the appellant&#039;s position debatable and no wilful suppression. Demands for service tax on directors&#039; remuneration were set aside as not raised in the SCN and comparable tribunal precedents supported the appellant. Relying on the SEZ Act and rules, the appellant was entitled to upfront, complete exemption for services received for authorised SEZ operations, and the appeals were allowed.</description>
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      <title>2025 (10) TMI 680 - CESTAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=779884</link>
      <description>CESTAT CHENNAI - AT held that the overseas entities were the employers and their transfer of expatriates to the appellant constituted supply of manpower services. The Tribunal declined invocation of the extended limitation period, finding the appellant&#039;s position debatable and no wilful suppression. Demands for service tax on directors&#039; remuneration were set aside as not raised in the SCN and comparable tribunal precedents supported the appellant. Relying on the SEZ Act and rules, the appellant was entitled to upfront, complete exemption for services received for authorised SEZ operations, and the appeals were allowed.</description>
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      <pubDate>Tue, 02 Sep 2025 00:00:00 +0530</pubDate>
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