No Service Tax on payments for Certification Services rendered by Foreign Entities in absence of fixed place of

The ITAT ruled that service tax does not apply to payments made for certification services provided by foreign entities if these entities do not have a fixed place of business in India. The decision highlights that in the absence of a permanent establishment in India, the services are not subject to Indian service tax under the relevant provisions. This ruling aligns with the principle that service tax is levied based on the presence of a fixed place of business and the location of the service provider.