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    <title>2026 (5) TMI 371 - CESTAT CHENNAI</title>
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    <description>Direct assistance rendered by a visa facilitator to individuals for obtaining visas was treated as outside Business Auxiliary Service because the facilitator did not act on behalf of embassies as an agent of the principal, and prior circulars and coordinate bench rulings had already supported that view. The visa facilitation charges were therefore not liable to Service Tax. On limitation, prior correspondence, audit knowledge, and earlier show cause notices showed departmental awareness of the activity, so suppression or wilful misstatement was not established. The extended period of limitation was accordingly unsustainable, and the demand, penalties, and connected adverse findings did not survive.</description>
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      <description>Direct assistance rendered by a visa facilitator to individuals for obtaining visas was treated as outside Business Auxiliary Service because the facilitator did not act on behalf of embassies as an agent of the principal, and prior circulars and coordinate bench rulings had already supported that view. The visa facilitation charges were therefore not liable to Service Tax. On limitation, prior correspondence, audit knowledge, and earlier show cause notices showed departmental awareness of the activity, so suppression or wilful misstatement was not established. The extended period of limitation was accordingly unsustainable, and the demand, penalties, and connected adverse findings did not survive.</description>
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