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    <description>Services rendered in India to customers of an overseas parent under a cost-plus arrangement were classified as Business Auxiliary Service because they were performed on behalf of the foreign client, rather than as Management, Maintenance or Repair Service. The overseas location of the service recipient and receipt of consideration in convertible foreign exchange satisfied the applicable export conditions, so the services qualified as export of service. A later service tax demand on similar facts was also time-barred because the department had previously issued a notice covering an earlier period, leaving no sustainable basis to invoke the extended limitation period. The service tax demands were set aside.</description>
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