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TMI Blog2010 (6) TMI 269X X X X Extracts X X X X X X X X Extracts X X X X ..... hing centre in terms of section 165(105)(zzc) of the Finance Act, 1994 read with section 65(26) and section 65(27) of the said Act. X X X X Extracts X X X X X X X X Extracts X X X X ..... ) Indian School of Business v. CC&CE [2009] 22 STT 189 (Bang. - CESTAT). 2. According to the learned Counsel, education does not include training. If there is no training imparted, mere education imparted by the appellant shall not amount to any service liable to tax under section 65(105)(zzc) of the Finance Act, 1994; so also his further submission is that this particular appellant has its own d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... liability which was submitted to the department on 18-1-2007. The learned Counsel submits that if non-taxable elements are removed, the tax liability, if any, shall be limited to Rs. 8 lakhs. 4. The learned Jt. CDR, opposing all the contentions of the learned Counsel, submits that page 56 of the brochure, which is referred to by the learned Counsel at page 43 of the appeal folder, categorically s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the appellant whether forms part of record of adjudication. Therefore, the certification was called for from the appellant. Taking this certification, prima facie it is proper to come to a conclusion that the appellant should not unduly suffer due to non-taxable element included for levy. At this stage believing the averment of the learned Counsel that tax liability may be limited to Rs. 8 lakhs ..... X X X X Extracts X X X X X X X X Extracts X X X X
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