9911796707
TMI Blog2017 (12) TMI 15X X X X Extracts X X X X X X X X Extracts X X X X ..... M/s. DHS have no arrangement with such company to enable the appellant to render any service on behalf of DHS - There is some element of confusion in the original authority's finding to identify the actual client itself. The appellants are providing service to M/s.DHS and DHS are their client. The company whose books are audited are not the client of the appellant. While they are clients of DHS a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in similar activity of auditing accounts of clients. Based on the arrangement, M/s.DHS gave some work to the appellant which is part of the inspection and audit of accounts of clients of M/s.DHS. The Revenue entertained a view that appellant provided Business Auxiliary Service (BAS) in terms of Section 65 (19) of Finance Act,1994, more specifically on behalf of the client. Accordingly, proce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mitted that there is no pre-existing tripartite arrangement involving the appellant, BHS and companies whose books are audited. The ld. counsel strongly contested the findings of the original authority and submitted that the whole conclusion is without support of law. 4. The Ld. A.R submitted that the appellant provided services to ultimate customer whose accounts were audited by the appell ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... even M/s.DHS have no arrangement with such company to enable the appellant to render any service on behalf of DHS. The arrangement between M/s.DHS and the appellant are on principal to principal and there is no tripartite prior arrangement in rendering any services. As such, the appellants are not providing any service on behalf of the client. There is some element of confusion in the original ..... X X X X Extracts X X X X X X X X Extracts X X X X
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