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    <title>2025 (12) TMI 516 - CESTAT MUMBAI</title>
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    <description>CESTAT Mumbai held that services rendered by the appellant to its foreign group entities constituted export of services under the Export of Services Rules, 2005, as the recipients were located abroad and consideration was received in convertible foreign exchange. The appellant was not acting as an intermediary. Operating fees collected from hotel owners could not include salaries of the hotel owners&#039; employees, which were treated as pure agent expenses and excluded from taxable value. Reimbursement of expenses in foreign currency under cost-sharing arrangements was also not liable to service tax. Consequently, the demand of service tax, interest, and penalties was found unsustainable and the appeals were allowed.</description>
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    <pubDate>Wed, 03 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 516 - CESTAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=782976</link>
      <description>CESTAT Mumbai held that services rendered by the appellant to its foreign group entities constituted export of services under the Export of Services Rules, 2005, as the recipients were located abroad and consideration was received in convertible foreign exchange. The appellant was not acting as an intermediary. Operating fees collected from hotel owners could not include salaries of the hotel owners&#039; employees, which were treated as pure agent expenses and excluded from taxable value. Reimbursement of expenses in foreign currency under cost-sharing arrangements was also not liable to service tax. Consequently, the demand of service tax, interest, and penalties was found unsustainable and the appeals were allowed.</description>
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