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TMI Blog2015 (3) TMI 964X X X X Extracts X X X X X X X X Extracts X X X X ..... called "Suspense account" or by any other name - amount relating to transaction with associated enterprises - Held that:- Law is well settled that amendment to law can be made retrospectively even bringing an amendment to an Explanation appearing in the statute. But the nature and character of the amendment decides whether such amendment is declaratory or clarificatory and accordingly whether retr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the statute book. Accordingly, there shall be no liability to levy of interest on the gross value of taxable service relating to the period prior to that date. - Decided in favour of assessee. - Appeal No.ST/00655/2010 - Final Order No. 41022/2014 - Dated:- 23-12-2014 - D. N. Panda And R. Periasami,JJ. For the Appellant : Mr G Natarajan, Adv. For the Respondent : Mr M Rammohan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (S.C.) . 2. The addition to the explanation as above was recognized for the first time in law with effect from 10.05.2008 . Such an incorporation gives rise to the determination of liability bringing a change to concept of gross value of taxable service provided by the service provider while dealing with the associated enterprises. 3. Law is well settled that amendment to law can be made ret ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tions in two different pattern was enacted from two different dates. Therefore, the addition to the Explanation (C) with effect from 10.05.2008 is prospective in nature and that addition shall be applicable from the day that was enacted in the statute book. Accordingly, there shall be no liability to levy of interest on the gross value of taxable service relating to the period prior to that date. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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