TMI Blog2010 (1) TMI 392X X X X Extracts X X X X X X X X Extracts X X X X ..... pellant. Shri S.R. Meena, SDR, for the Respondent. [Order per : D.N. Panda, Member (J)]. - Ld. Counsel, Shri S.K. Pahwa submits that entire object behind availing service of Japanese concern was to share technical expertise achieved by that Japanese concern. For such expertise, consideration was paid. Revenue claims that service provided by Japanese concern was consultancy engineering service. B ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e was provision of technical assistance, guidance, advice and training to the engineers and personnel of the appellants specifically as per provisions made in Article 3 of the agreement between the parties. Further, observation of the Commissioner (Appeals) shows that there was no technical support. It is therefore not possible to comprehend how technical knowhow was provided by the Japanese conce ..... X X X X Extracts X X X X X X X X Extracts X X X X
|