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TMI Blog2014 (11) TMI 121X X X X Extracts X X X X X X X X Extracts X X X X ..... Jagdish, Superintendent, for the Respondent. ORDER Demand for service tax of Rs. 2,11,38,195/- has been made against the appellant with interest on the ground that appellant had received services from abroad from their own branches and others through their branches and are liable to pay service tax on the same. The period involved is 2006-07 to 2010-11. In addition, an amount of Rs. 19,51,207/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the show cause notice wherein services received have been classified under various services. However, we find that demand has been made on the ground that the offices abroad are not permanent establishments but this observation has no foundation since no evidence have been gathered or indicated in the findings at all. The learned counsel on the other hand relied upon the definition of permanent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the Revenue has made out a case of offence against the appellant on a prima facie basis. As regards the service tax credit on construction service, the inclusive definition of 'input services' clearly covers service tax paid on construction of factory during the relevant period. That being the position, the credit is prima facie admissible. In view of the above, the appellant has made out a pr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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