TMI Blog2008 (10) TMI 680X X X X Extracts X X X X X X X X Extracts X X X X ..... petitioner and the learned counsel appearing on behalf of the respondents. 2. It is stated that the petitioner is a Registered Company. A technical knowhow agreement was entered into between the Petitioner-Company and a Canadian Company incorporated in the State of Tamil Nadu, under which the Canadian Company was to provide technical know-how and expertise on various matters relating to the pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ective from the year 1997. However, there was no rendering of services by the Canadian Government [company] within the territory of India, attracting liability to Service Tax. Accordingly, no provision was made for the payment of service tax and it was well within the knowledge of the first and second respondents. However, by a letter, dated 5-12-2002, in C. No. IV/16/2002/STU, issued by the Super ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... before the issuance of the impugned letter, dated 5-12-2002, by the second respondent. However, he had submitted that the respondents may be permitted to issue a notice to the petitioner, with regard to the demand for payment of service tax, in accordance with law. 5. In view of the submissions made by the learned counsels for the petitioner, as well as for the respondents, the impugned letter ..... X X X X Extracts X X X X X X X X Extracts X X X X
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