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    <description>Services performed for South Western Railway were treated as maintenance, overhaul and testing integral to railway operations, so they fell within management, maintenance or repair of railways and qualified for exemption under Notification No. 24/2009-ST despite procedural invoice defects. Services supplied to a foreign principal under the DAMEL subcontract were treated as export of services because the recipient was outside India and consideration was received in convertible foreign exchange; the place of performance was not decisive, and lack of privity with the Indian project entity did not change that character. The demand was also held time-barred because the transactions were disclosed in books and returns, with no suppression or intent to evade, and the penalty could not survive.</description>
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