TMI Blog2013 (11) TMI 709X X X X Extracts X X X X X X X X Extracts X X X X ..... e case of Anuradha Jain Vs. CCE, Bhopal [2008 (7) TMI 43 - CESTAT, NEW DELHI] and CCE, Jaipur Vs. R.S. Financial Services [2007 (10) TMI 392 - CESTAT, NEW DELHI] that a proprietorship concern is to be considered as commercial concern for the purpose of interpreting different clauses in Section 65(105) of the Finance Act, 1994 wherever the expression commercial concern was used during the relevant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd Rs.1,61,401/- against M/s. Saratha Works along with interest and penalties. Aggrieved by the order of the Commissioner (Appeals), the applicants have filed these appeals along with stay applications. 2. The contention of the counsel is that the activity of manpower supply was taxable only if it was done by a commercial concern till 16.6.2006. After that date such services rendered by any pers ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R.S. Financial Services 2008 (9) STR 231 that a proprietorship concern is to be considered as commercial concern for the purpose of interpreting different clauses in Section 65(105) of the Finance Act, 1994 wherever the expression commercial concern was used during the relevant period. 4. Considered arguments on both sides. We find force in the submission of the learned AR for Revenue and we dir ..... X X X X Extracts X X X X X X X X Extracts X X X X
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