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TMI Blog2014 (7) TMI 370X X X X Extracts X X X X X X X X Extracts X X X X ..... ges, provide technology up-gradation plan, research and development plan, customer’s project execution plan etc. in order to diagnose the operational problems and provide solutions in time. The services being provided by the Respondent are clearly covered by the definition of ‘Management Consultancy Services’ under section 65(65) of the Finance Act, 1994. CST, Mumbai Vs. Essel Corporate Services Pvt. Ltd. reported in [2014 (6) TMI 136 - CESTAT MUMBAI]. impugned order setting aside the service tax demand is not correct. Extended period of limitation - since the Respondent are a Public Section Undertaking, the longer limitation period for demand of non-paid service tax under proviso to section 73(1) would not be invokable, as in the circu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ke timely corrective actions in case of slippages; (ii) review the performance-targets of the subsidiaries; (iii) provide technology up-gradation plan; (iv) provide research and development plan; (v) review customers project execution plan; (vi) provide consultancy study plan in order to diagnose the operational problems as well as analyze internal and external environments, markets etc. 1.2 The Respondent for the above services in respect of their subsidiaries were charging an amount as Management Consultancy Services charges. The Department was of the view that the Respondent have provided the management consultancy service taxable under section 65(105)(V) read with section 65(65) of the Finance Act, 1994 to their su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sahay, the learned DR, who assailed the impugned order by reiterating the grounds of Revenue s appeal and pleaded that the Respondent and their subsidiaries are two independent legal entities and findings of the Commissioner (Appeals), that there is no service provider and client relationship between them is not correct. He also emphasized that the services provided by the Respondent are covered by the definition of Management Consultancy Services under section 65(65) of the Finance Act, 1994. He, therefore, pleaded that the impugned order is not correct. 4. We have considered the submissions of the learned DR and have gone through the records of this case. The Respondent as holding company of their subsidiary companies as mentioned a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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