BAS services to group companies outside India on principal to principal basis cannot be treated as ‘Intermediary Services’

CSG Systems International (India) Pvt Ltd. Vs Commissioner of Central Tax Bengaluru South Commissionerate (CESTAT Bangalore) I find that when the show-cause notice dt. 28/03/2014 was issued when the appellant filed the refund claim and the grounds raised in the show-cause notice was lack of nexus, claim is time barred and lack of documentation or discrepancies in documents; whereas when the Order-in-Original dt. 16/01/2018 was passed, the original authority travelled beyond the show-cause notice and came to a finding that the sales, marketing and administrative services are classified as BAS p...