2011 (4) TMI 655

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..... sioner, the Revenue has filed the appeal. 2. We have heard Shri K.K. Jaiswal, learned DR and Shri Manish Saharan, learned Advocate. 3. As per the facts on record, the respondent is engaged in the manufacture of engines/transmission and power units of motor vehicles. They obtained technical assistance from M/s Mitsuibishi Motor Corporation, Japan and M/s Oka Motor Company Ltd. Australia. Agreemen .....

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..... est and imposition of penalty of identical amounts under Section 78 of the Act. On appeal against the above order, the Commissioner (Appeals) observed that the services provided by the said foreign companies can be considered as falling under the 'Consulting Engineer' services. He also relied upon his earlier order dated 18.5.2007 and held that the payment of royalty by the respondents cannot be c .....

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