https://www.taxtmi.com/caselaws?id=791165 Services rendered under an MOU to support and service customers of an overseas parent company were treated as service on behalf of the client, not as Management, Maintenance or Repair Service. Because the recipient was outside India and consideration was received in convertible foreign exchange, the activity satisfied the conditions for export of service under Rule 3(1)(iii) of the Export of Services Rules, 2005. The note also records that a later demand was held time-barred where the department had already issued an earlier notice on similar facts, so extended limitation was not available without a legally sustainable basis. en-us Mon, 12 Jan 2026 00:00:00 +0530 Wed, 06 May 2026 11:47:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791165 Services rendered under an MOU to support and service customers of an overseas parent company were treated as service on behalf of the client, not as Management, Maintenance or Repair Service. Because the recipient was outside India and consideration was received in convertible foreign exchange, the activity satisfied the conditions for export of service under Rule 3(1)(iii) of the Export of Services Rules, 2005. The note also records that a later demand was held time-barred where the department had already issued an earlier notice on similar facts, so extended limitation was not available without a legally sustainable basis. Case-Laws Service Tax Mon, 12 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791165