TMI Blog2014 (8) TMI 855X X X X Extracts X X X X X X X X Extracts X X X X ..... service from outside India came into effect from 18.4.2006 and the period involved in this case is prior thereto, the demand confirmed cannot survive. The issue is no longer res integra to warrant elaborate discussion. It is nonetheless dismaying to note that neither the Show Cause Notice nor the order-in-original/order-in-appeal even remotely mention the legal provision under which the recipients ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... agreement with M/s Thai Stanley Electric Public Company Ltd., Thailand with head office in Thailand for providing technical advice and instructions so that the appellants would be able to manufacture auto parts for Hero Honda Company with satisfactory quality. The appellants paid ₹ 35,20,000/- during the period 2004-2005 as technical knowhow fees in foreign currency to the aforesaid Thai C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rd to the fact that Section 66A of the Finance Act 1994 giving the authority to charge service tax from the service recipient in case of receipt of service from outside India came into effect from 18.4.2006 and the period involved in this case is prior thereto, the demand confirmed cannot survive. The issue is no longer res integra to warrant elaborate discussion. It is nonetheless dismaying to no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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