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TMI Blog2011 (7) TMI 887X X X X Extracts X X X X X X X X Extracts X X X X ..... Rule 2 (1) (d) (iv) did not have virus to tax the services rendered by a person located outside India in the hands of the person receiving such service in India. - Since the entire period involved in this dispute is prior to 18-04-2006, the Appeal succeeds on this count alone. X X X X Extracts X X X X X X X X Extracts X X X X ..... the recipient of the service. 3.The Appellant had contested that the first component of the payment was towards sponsorship fees paid to Global Cricket Corporation PTE Ltd and World Sports Nimbus PTE Ltd for sponsorship of Cricket World Cup and other tournaments organized by International Cricket Council, abroad. According to them these services were performed outside India and hence there was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Education cess of Rs. 5,78,680/- was confirmed along with interest as per details below: Details of Service tax payable in respect of payments made to foreign service providers on advertisements, publicity and sales promotion as well as on 'Research & Development' Year Amount Paid on advt. publicity and sales promotion Amount paid on R&D Total (A+B) Rate of service tax Amount of service ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section 66A was introduced in Finance Act 1994, the provisions in Rule 2 (1) (d) (iv) did not have virus to tax the services rendered by a person located outside India in the hands of the person receiving such service in India. 9. Since the entire period involved in this dispute is prior to 18-04-2006, the Appeal succeeds on this count alone and we do not consider it necessary to examine the oth ..... X X X X Extracts X X X X X X X X Extracts X X X X
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