TMI Blog2014 (3) TMI 227X X X X Extracts X X X X X X X X Extracts X X X X ..... anager, Taxation, for the Appellant. Shri Pramod Kumar, Jt. CDR, for the Respondent. ORDER After hearing both the sides, we find that the appellant was discharging his Service Tax liability in respect of consulting engineer services received by them from foreign countries. Such Service Tax was being paid on reverse charge basis and the appellant was availing the credit of the same. 2. Pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e tax. Accordingly, he confirmed the demand of Service Tax of Rs. 6,73,96,506/- by denying them the Cenvat credit and imposed penalty of Rs. 7,00,00,000/-. 4. At this interim stage, we note that admittedly the appellant has paid the service tax, in question, and has taken the credit of the same. Revenue while denying the credit has not disputed the service tax "paid" by the appellant. If the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aid cannot be held to be against the law so as to deny them the credit. 6. We also further note that the said proposal of denial of credit in the show cause notice was on altogether different ground, which, in any case stand accepted by the Adjudicating Authority. He cannot move from the allegation made in the notice and cannot adopt a different ground for denial of the credit, according to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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