2010 (3) TMI 439

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..... amended only with effect from 16-6-2005 vide Notification 19/2005-S.T., dated 7-1-2005 to cover the production of goods ‘for or on behalf of their clients’. Held that- the appellants have made out a prima facie case on merits in the light of the Tribunal’s decision and in the absence of any finding by the authorities below on the argument that the production of goods by the assessee was only for .....

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..... ice covered the period from 10-9-2001 to 31-3-2006) but the Commissioner (Appeals) reduced the penalty. 2. The submission of the assessee is that they were producing goods for their clients and not on behalf of their clients and therefore not liable to pay Service tax for the period from 16-6-2005 as the definition in the Finance Act was amended only with effect from 16-6-2005 vide Notification .....

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..... below, both on merits of the demand as well as on limitation. 4. After careful consideration of the submissions made by both sides, we find that the appellants have made out a prima facie case on merits in the light of the Tribunal's decision and in the absence of any finding by the authorities below on the argument that the production of goods by the assessee was only for the client during the .....

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