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    <title>2026 (1) TMI 1013 - CESTAT NEW DELHI</title>
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    <description>Whether a provider of data hosting qualifies as an intermediary under the Place of Provision of Service Rules was examined; the provider was not an agent, did not arrange or facilitate services between third parties, and rendered hosting on its own account, therefore it falls outside the definition of intermediary and the place of provision follows the general rule locating the recipient abroad, rendering the services exported and outside domestic service tax. Invocation of extended limitation was rejected as exceptions did not apply and bona fide belief in export treatment negated suppression. A remand was directed solely to determine whether interest on previously paid marketing-service tax was paid before issuance of the show cause notice.</description>
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