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Appellant Exempt from Service Tax on Foreign-Based Tangible Goods; Relies on Proviso to Rule 3(iii).

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....Supply of Tangible Goods service - place of provision of services - the wagon are not located during the entire period by the appellant within the territory of India so the appellant is not liable to pay service tax under the reverse charge mechanism in view of the proviso to Rule 3(iii). - AT....