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    <title>2025 (11) TMI 857 - CESTAT NEW DELHI</title>
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    <description>CESTAT held the contracts were single contracts partly performed outside India and partly onshore; services performed beyond territorial waters are not exigible, but where part performance occurred in India the service is treated as rendered in India for valuation. Section 66A makes the service recipient liable when the provider is located outside India. Consequently the tax demand against the local appellant was set aside and liability rests on the Indian service recipients. Applicable rate affirmed at 12% of the value of taxable services.</description>
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      <title>2025 (11) TMI 857 - CESTAT NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=781389</link>
      <description>CESTAT held the contracts were single contracts partly performed outside India and partly onshore; services performed beyond territorial waters are not exigible, but where part performance occurred in India the service is treated as rendered in India for valuation. Section 66A makes the service recipient liable when the provider is located outside India. Consequently the tax demand against the local appellant was set aside and liability rests on the Indian service recipients. Applicable rate affirmed at 12% of the value of taxable services.</description>
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