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2013 (9) TMI 143

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..... Archana Wadhwa: Total service tax demand confirmed against the appellant is Rs.9 ,22,496 /- with an equal amount of penalty imposed under Section 78 of the Finance Act and penalty of Rs.5,000/- imposed under Section 77. 2. After hearing both the sides, we find that the appellant is a registered Service Tax provider under the category of Event Management and were discharging their service tax lia .....

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..... ed the benefit of the said notification to the appellant on the ground that the services does not stand provided by them directly but they have provided the services to M/s. Lintas who had further provided the said services of M/s. Unicef . On this issue, we note that the notification in question exempted services provide by any person to Unicef . As per the appellant, they have not provided a pa .....

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..... ral Communication Marketing Pvt. Ltd. have paid the service tax on the entire value of the services provided by them to their clients. As such the confirmation of the service tax in respect of the part of the services being provided by the appellant to M/s. Rural Communication Marketing would amount to double taxation. The said plea of the appellant does not stand rebutted by the lower authorities .....

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..... ocation of extended period. We note that the issue involved is of technical nature and require legal interpretation. Inasmuch as the entire service tax demand was being paid by M/s. Rural Communication Marketing Pvt. Ltd. in this case, the service were being provided to Unicef in the second case, and as such can lead to a bona fide belief on the part of the assessee to entertain a view that no fur .....

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