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TMI Blog2017 (4) TMI 856X X X X Extracts X X X X X X X X Extracts X X X X ..... provided u/s 66A of the FA, 1994 - the entire service tax along with interest thereof has already been paid by the appellant on being pointed out. Since the appellant has already paid the entire tax liability along with interest before issuance of show cause notice, we find that the ratio of the decision of the Hon’ble High Court of Karnataka in the case of Commissioner V. Manipal County [2011 (9 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the Commissioner of Central Excise (LTU), Mumbai. 2. The relevant facts that arise for consideration, after filtering out unnecessary details, are that the appellant is engaged in the manufacture of bulk drugs has units all over the country and has registered office in Mumbai holding ISD registration and availed various services from overseas party. The payments made to the overseas parties ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g with interest thereof for the period 18/04/2006 onwards on the amounts paid by them to the overseas service providers as provided under Section 66A of the Finance Act, 1994. It is also the claim that during the relevant period the law was in fluid state and hence there was no clarity till the Hon ble High Court of Bombay pronounced the verdict in the case of Indian National Shipowner s Associa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TR J188 (Kar.), will apply. In these two judgments the Hon ble High Court has held that provisions of Section 73(3) of the Finance Act, 1994 will be applicable in cases wherein appellant has discharged service tax liability and the interest thereof on being pointed out by the authorities before the issuance of the show cause notice, and there is no necessity to issue show cause notice for penalt ..... X X X X Extracts X X X X X X X X Extracts X X X X
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