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    <title>2026 (7) TMI 161 - CESTAT CHANDIGARH</title>
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    <description>Services wholly performed and consumed outside India, including inspection, sorting, rework, warehousing and related handling of exported goods, were held not taxable under reverse charge because Section 66A of the Finance Act, 1994 and Rule 3(ii) require receipt of service in India. A best judgment assessment under Section 72 was described as unsustainable where it was based on extrapolated figures and assumptions unsupported by proof of actual remittances. The extended limitation period was also stated to be unavailable absent positive suppression with intent to evade, particularly where audits, returns and departmental scrutiny already disclosed the relevant facts.</description>
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