2014 (8) TMI 513

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..... at for levying Service Tax there should be two different legal entities involved — one providing service to the other - Held that:- Delhi office and the corporate office located at Japan are two offices of the same company. In such a situation, prima facie there cannot be any service by corporate office in Japan to Delhi office. Prima facie the demand is not maintainable. Therefore, there shall be .....

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..... so for payment of income-tax as per provision of Double Taxation Avoidance Agreement. The Revenue has made out a case that the local Delhi office has been receiving service of manpower supply from the head office located in Japan and therefore the Delhi office should pay the service tax under Section 66A of the Finance Act, 1994 as recipient of services. 2. The counsel for the appellant submits .....

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