2012 (1) TMI 33

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..... res integra. Any service provided to the assessee by a non-resident prior to insertion of Section 66A of the Finance Act, 1994, was not exigible to service tax. See CCE vs M/s Kansal Hosiery Exports (2012 - TMI - 208473 - Punjab And Haryana High Court ), CCE v. Bhandari Hosiery Exports Ltd. (2009 - TMI - 35335 - Punjab And Haryana High Court ), Indian National Shipowners Association v. Union of In .....

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..... ion of Section 66A in the Finance Act, 1994 . It was by the aforesaid provision that the service tax was levied. The provision was introduced on 18.4.2006. The Tribunal by placing reliance on a judgement of the Bombay High Court rendered in the case of Indian National Shipowners Association v. Union of India, 2009 (13) STR 235 (Bom.) has held that any transaction prior to 18.4.2006 will not be exi .....

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..... STR 713 (P H) as also the view taken by the Bombay High Court in the case of Indian National Shipowners Association (supra), we came to the conclusion that any service provided to the assessee-respondent by a non-resident prior to insertion of Section 66A of the Finance Act, 1994, was not exigible to service tax. Accordingly we dismissed the aforesaid appeal of the revenue, vide judgment dated 2. .....

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