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    <title>2025 (11) TMI 1704 - CESTAT HYDERABAD</title>
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    <description>CESTAT Hyderabad held that the appellant&#039;s services to foreign entities in Germany and China constituted export of services and were not liable to service tax. Applying Rule 3 of the Place of Provision of Services Rules, 2012, the Tribunal found that the place of provision was the location of the service recipients outside India. The appellant was not an &quot;intermediary&quot; under Rule 2(f) during the relevant period, as it did not merely arrange or facilitate services. Consequently, the Finance Act, 1994 was inapplicable, and the service tax demand, interest, and penalties were set aside, allowing the appeal.</description>
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    <pubDate>Tue, 25 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 1704 - CESTAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=782236</link>
      <description>CESTAT Hyderabad held that the appellant&#039;s services to foreign entities in Germany and China constituted export of services and were not liable to service tax. Applying Rule 3 of the Place of Provision of Services Rules, 2012, the Tribunal found that the place of provision was the location of the service recipients outside India. The appellant was not an &quot;intermediary&quot; under Rule 2(f) during the relevant period, as it did not merely arrange or facilitate services. Consequently, the Finance Act, 1994 was inapplicable, and the service tax demand, interest, and penalties were set aside, allowing the appeal.</description>
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      <pubDate>Tue, 25 Nov 2025 00:00:00 +0530</pubDate>
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