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    <title>2025 (11) TMI 437 - CESTAT CHANDIGARH</title>
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    <description>Services rendered for foreign recipients were treated as export of service where the recipient and effective benefit were outside India and consideration was received in convertible foreign exchange. Business auxiliary and business support services supplied for overseas use therefore fell within the export framework under Rule 3. The text also notes that service tax could not be extended to reimbursed expenses beyond the charging provision, and that trading activity for the period before 01.04.2011 could not be treated as exempted service to deny Cenvat credit, since the later explanation operated prospectively. In the absence of wilful suppression or intent to evade, extended limitation and penalties were not supportable.</description>
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      <description>Services rendered for foreign recipients were treated as export of service where the recipient and effective benefit were outside India and consideration was received in convertible foreign exchange. Business auxiliary and business support services supplied for overseas use therefore fell within the export framework under Rule 3. The text also notes that service tax could not be extended to reimbursed expenses beyond the charging provision, and that trading activity for the period before 01.04.2011 could not be treated as exempted service to deny Cenvat credit, since the later explanation operated prospectively. In the absence of wilful suppression or intent to evade, extended limitation and penalties were not supportable.</description>
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