https://www.taxtmi.com/caselaws?id=782230 CESTAT Mumbai allowed the appeal, holding that the services provided to the foreign recipient did not qualify as "intermediary services" under Rule 2(f) of POPS, 2012. The Tribunal found no involvement of three parties, no distinct main and ancillary supplies, and no principal-agent relationship under the contracts. Applying CBIC Circular dated 20.09.2021 and Rule 6A of the Service Tax Rules, 1994 read with Rule 3 of POPS, 2012, it held the services were exports. Consequently, Rule 9 of POPS was inapplicable, and the denial of refund of unutilized CENVAT credit was unsustainable. The impugned order was set aside and refunds restored. en-us Wed, 19 Nov 2025 00:00:00 +0530 Thu, 27 Nov 2025 08:36:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782230 CESTAT Mumbai allowed the appeal, holding that the services provided to the foreign recipient did not qualify as "intermediary services" under Rule 2(f) of POPS, 2012. The Tribunal found no involvement of three parties, no distinct main and ancillary supplies, and no principal-agent relationship under the contracts. Applying CBIC Circular dated 20.09.2021 and Rule 6A of the Service Tax Rules, 1994 read with Rule 3 of POPS, 2012, it held the services were exports. Consequently, Rule 9 of POPS was inapplicable, and the denial of refund of unutilized CENVAT credit was unsustainable. The impugned order was set aside and refunds restored. Case-Laws Service Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782230