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TMI Blog2011 (4) TMI 913X X X X Extracts X X X X X X X X Extracts X X X X ..... REME COURT] that till the time Section 66A was enacted i.e.earlier to 18.4.2006 only the person who rendered the service was liable to pay tax and not the recipient of the service from a person resident outside India - in favour of the assessee - 2336/2010 - 346/2011 - Dated:- 25-4-2011 - P Karthikeyan, M V Ravindran, JJ. For Appellants : Ms Mekhla Anand and Mr Sandeep Chilana, Advs. Fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ould also submit that in a recent judgment arising out of a SLP filed before the Hon'ble Supreme Court in the case of Commissioner Vs. Bhandari Hosiery Exports Ltd. [2010 (20) STR J99 (SC)], the issue stands covered in their favour. 5. The learned JCDR, on the other hand, would submit that the person who provided services to the appellant does not have any office or establishment in India and he ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rson who is situated abroad. This bench has been taking a consistent view that prior to 18.04.2006, such service tax liability does not arise in the hands of the recipient of the services. We also find that the judgment of this bench has been upheld by the Hon'ble High Court of Karnataka in the case of CST, Bangalore Vs. Toyoda Iron Works Co. Ltd. [2010 (19) STR 802 (Kar)]. We also find that the A ..... X X X X Extracts X X X X X X X X Extracts X X X X
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