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TMI Blog2017 (3) TMI 865X X X X Extracts X X X X X X X X Extracts X X X X ..... ef facts of the case are that the department had taken the view that appellant should have discharged service tax liability under reverse charge basis as per Rule 2 (1)(d)(iv) of Service Tax Rules, 1994, under Franchise Service for the fees paid to M/s. Meridian S.A. France, based on the agreement entered with them. In the adjudication proceedings, the original authority confirmed the demand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty sanctioned refund of Rs. 20,69,124/- only. Department preferred an appeal against this sanction order to the ld. Commissioner (Appeals), who vide the impugned order dated 27.10.2015 allowed the appeal of the department, interalia, which is reproduced as follows:- "6 (iv) The facts not in dispute in the present case is that the service provider namely M/s. Meridian S.A. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rvice tax liability in such cases arise with effect from 01.01.2005. He further submits that since the relevant Section 66A was inserted in the Act only from 18.04.2006, service tax liability thereon will arise only from that date. 3. Ld. AR Shri S. Govindarajan, AC, fairly concedes that tax liability under Section 66A will indeed arise from 18.04.2006 only. 4. In the event, I find that th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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