Dispute Over Service Tax Classification: Are Services to Overseas Parent Company Exports? Examining Section 65B(44) and Rule 6A.

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....Export of services or not - Services provided outside India - Parent Company / 100% holding company - Distinct Person or not - POPOS Rules - It appears that the respondents have assumed the jurisdiction on mere misinterpretation of the provisions of explanation 3 (b) to Section 65B(44) of the Act,1994 read with Rule 6A of the Rules, 1994 as by no stress of imagination, it can be said that the rendering of services by the petitioner No.1 to its parent Company located outside India was service rendered to its other establishment so as to deem it as a distinct person as per Item (b), explanation 3 of clause (44) of Section 65B of the Act, 1994 - HC....