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    <title>2026 (5) TMI 1097 - CESTAT ALLAHABAD</title>
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    <description>Service tax under reverse charge was found payable only where the department established that the payment related to a taxable service received in India or deemed received under the place-of-provision rules. Foreign currency remittances linked to import of goods, unidentified transactions, provisional or accrual entries, and pure reimbursements were not enough to attract tax. Expenses for events, exhibitions, accommodation, sponsorship and similar activities performed outside India were treated as outside the charge because the place of provision was abroad. The commentary also notes that revenue neutrality and a dispute turning on statutory interpretation weighed against invocation of the extended limitation period.</description>
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      <description>Service tax under reverse charge was found payable only where the department established that the payment related to a taxable service received in India or deemed received under the place-of-provision rules. Foreign currency remittances linked to import of goods, unidentified transactions, provisional or accrual entries, and pure reimbursements were not enough to attract tax. Expenses for events, exhibitions, accommodation, sponsorship and similar activities performed outside India were treated as outside the charge because the place of provision was abroad. The commentary also notes that revenue neutrality and a dispute turning on statutory interpretation weighed against invocation of the extended limitation period.</description>
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