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    <title>2026 (2) TMI 237 - CESTAT CHANDIGARH</title>
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    <description>Liability to pay service tax for commission earned from foreign universities was examined under the Place of Provision of Services Rules, 2012 and the definition of intermediary. The tribunal applied precedent concluding the appellant&#039;s activities do not constitute intermediary service but qualify as export of services under Rule 3, with the consequence that tax demands were not sustainable and were set aside on merits. Because the appeal succeeded on the substantive classification, other issues (including limitation under the extended period) were not decided; appeals were allowed with consequential relief as per law.</description>
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      <description>Liability to pay service tax for commission earned from foreign universities was examined under the Place of Provision of Services Rules, 2012 and the definition of intermediary. The tribunal applied precedent concluding the appellant&#039;s activities do not constitute intermediary service but qualify as export of services under Rule 3, with the consequence that tax demands were not sustainable and were set aside on merits. Because the appeal succeeded on the substantive classification, other issues (including limitation under the extended period) were not decided; appeals were allowed with consequential relief as per law.</description>
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