Sub-contractor's services to SEZ units exempt from service tax; demand barred by limitation and appeal allowed.

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....Appellant provided services to SEZ units as sub-contractor, not liable to service tax as services wholly consumed by SEZ units. Location of service provider irrelevant for exemption under SEZ Act and Rules. Issue debatable, involving interpretation of complex laws. Extended period of limitation wrongly invoked, entire demand barred by limitation. Demand of service tax, interest, and penalty set aside. Appeal allowed.....