TMI Blog2015 (12) TMI 1218X X X X Extracts X X X X X X X X Extracts X X X X ..... n 65 (105)(zzzz) of Finance Act, 1994, there shall be taxability under the shelter of provision of services in relation to supply of tangible goods - Held that:- Prima facie, interpretation of law is involved in this case with the bundle of facts including contract documents touching the same. In respect of similar nature of transactions Tribunal in the case of Petronet LNG Ltd. Vs Commissioner of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hereof by the appellant in India without transfer of ownership of the boat to the appellant. There was effective control over the boat by the appellant. There is no finding in the Adjudication order as to any service element involved to show that the same was in respect of supply of tangible goods. When that lacks, there shall not be taxability relying on the decision of the Tribunal in the case o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had ownership thereof. Therefore, there shall be liability to tax. Similarly, when the boat came to India, and Customs duty as well as entry tax was paid for that, that formed part of the value of the boat. Therefore, that is in relation to supply of tangible goods. 4. Heard both sides and perused the records. 5. Prima facie, interpretation of law is involved in this case with the bundle of fac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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