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TMI Blog2012 (9) TMI 528X X X X Extracts X X X X X X X X Extracts X X X X ..... filed for waiver of pre-deposit of Service Tax of Rs.16,33,802/-, interest thereof and penalties under Sections 76 and 78 of Finance Act, 1994. 2. The above said amount is confirmed as Service Tax liability and penalties have been imposed and interest has been charged on the amount of Service Tax liability on the ground that the appellant has not discharged the Service Tax liability under the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 09 (240) ELT 135 (Tri-Ahmd) and in the case of MIDCO Ltd - and in the case of Shree Rama Multi-Tech Ltd -2009 (238) ELT 699 (Tri-Ahmd), has been taking a view that if an audit objection is raised and Show Cause Notice issued after a period of 2 years, extended period cannot be invoked. 5. Ld.Commissioner (A.R.), on the other hand, submits that on merit, the appellant has no case as the agreement ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n who wish to manufacture same product by using the process developed by the appellant herein. This itself would indicate that there is no permanent transfer of intellectual property right to the licencee in the agreement. Be that as it may, we are of the view the appellant has not made out a prima facie case for complete waiver of pre-deposit of the amounts involved. 7. On the question of limita ..... X X X X Extracts X X X X X X X X Extracts X X X X
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