TMI Blog2014 (7) TMI 822X X X X Extracts X X X X X X X X Extracts X X X X ..... Dixit, DR, for the Respondent. ORDER The prayer is to dispense with the condition of pre-deposit of Service Tax of Rs. 4,03,791/- alongwith penalty of identical amount under Section 75 and penalty of Rs. 5,000/- imposed under Section 77 of Finance Act, 1994. 2. After hearing both the sides, we find that the said tax stand confirmed proceeded against the applicant for the period 27th Septem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me taxable. As such, Tribunal held that the service cannot be held to have been rendered at the time when it became taxable. 5. The distinction drawn by the learned DR on the ground that it is technical knowhow service in the case of Denso Haryana Pvt. Ltd. v. CCE, Delhi-III (supra), whereas it is IPR service in the present case does not appeal to us. It is the ratio of law which is relevant ..... X X X X Extracts X X X X X X X X Extracts X X X X
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