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    <title>2026 (1) TMI 1524 - CESTAT HYDERABAD</title>
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    <description>Interpretation of &#039;used outside India&#039; under the Export of Service Rules: the benefit of a service must accrue outside India even if all activities occur in India. The second proviso to the relevant rule supplements, not replaces, the first proviso by treating services delivered to goods or property located abroad via electronic networks as performed outside India; that exception was inapplicable here. Applying these principles, technical testing and analysis services commissioned and utilised abroad qualify as export of service and are not taxable as service tax. The impugned assessment was set aside and the appeal allowed.</description>
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      <description>Interpretation of &#039;used outside India&#039; under the Export of Service Rules: the benefit of a service must accrue outside India even if all activities occur in India. The second proviso to the relevant rule supplements, not replaces, the first proviso by treating services delivered to goods or property located abroad via electronic networks as performed outside India; that exception was inapplicable here. Applying these principles, technical testing and analysis services commissioned and utilised abroad qualify as export of service and are not taxable as service tax. The impugned assessment was set aside and the appeal allowed.</description>
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