Companies Located Outside India To Be Treated As Distinct Person And Transaction Between Them Amounts To Export Of Service: CESTAT

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Companies Located Outside India To Be Treated As Distinct Person And Transaction Between Them Amounts To Export Of Service: CESTAT

Indirect Taxes

Published on

17/03/2026

By Mariya Paliwala

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The Delhi Bench of Customs, Excise and Service Tax Appellate Tribunal (CESTAT) has held that companies located outside India/non-taxable territories are to be treated as distinct persons and the transaction between them shall be qualified to be called as Export of Service. The bench of Dr. Rachna Gupta (Judicial Member) has observed that the appellant/service…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

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Export Of Service

Companies Located Outside India To Be Treated As Distinct Person And Transaction Between Them Amounts To Export Of Service: CESTAT

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