Patent transfer before tax inclusion and from outside India means no service tax; installment payments don't make it continuous

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....CESTAT allowed the appeal and set aside the impugned order, holding that the taxable event (transfer of patent/IPR) occurred prior to inclusion of IPR services within the service tax net and was rendered from outside India, so no service tax liability arose. The Tribunal found no evidence that the liaison office in India rendered the services or received consideration in INR; the adjudicating authority erred in treating a one-time transfer as a continuous taxable activity merely because consideration was payable in installments. Consequently the extended limitation invocation and demand (including Rs. 1,64,789 claimed as out-of-pocket recoupment under valuation rules) were unsustainable and the demand is set aside.....