2013 (12) TMI 913

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..... hat:- In such matters involving different views given by Tribunal invoking extended period for demanding tax is prima facie not justifiable - Conditional stay granted.
P K Das And Shri Mathew John, JJ. For the Appellant : Shri Joseph Prabhakar, Adv. For the Respondent : Shri D P Naidu, Addl. Commr. (AR) PER : Mathew John The applicants are engaged in the business of repairing marine contain .....

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..... E - 2011 (23) STR 608 (Tri. - LB) is against him inasmuch as the Tribunal has decided that the chemicals used for providing the service of photography will from part of the value of services. However, he relies on the decision of the Tribunal in the case of Shobha Digital Lab Vs. CCE - 2011 (24) STR 430 wherein it was held that since there were many decisions to the effect that value of materials .....

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..... as not a bonafide or reasonable belief. He relies on the decisions of the Tribunal in the cases of Safety Retreading Company (P) Ltd. Vs. CCE - 2012 (26) STR 225 and Sayaji Hotels Ltd. Vs. CCE - 2011 (24) STR 177. 3. We have considered arguments on both sides. We find that this is an issue about which there were many decisions of the Tribunal in favour of the assessees and the conflict in the dec .....

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