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Service Tax Not Applicable on Third Party Payments for Exports Under 2012 Rules; Hong Kong Entity as Intermediary.

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....Levy of service tax - POPOS rules - Place of supply - Banking and other financial services - ‘third party payments’ for exports - It is not the contractual responsibility of the appellants to collect the dues and, therefore, by no stretch can it be held that the mediation of M/s Amsco Finance Ltd is a substitution for the task that would, otherwise, fall to the appellants. If at all, the Hong Kong entity is an ‘intermediary’ within the meaning assigned in Place of Provision of Service Rules, 2012 to render the service, it has been performed in Hong Kong and, thus, not in the taxable territory. - AT....