TMI Blog2008 (6) TMI 159X X X X Extracts X X X X X X X X Extracts X X X X ..... is in the nature of assistance to corporate advisory services - it cannot be said that services rendered by them related to either conceptualizing, devising, developing, modifying or upgrading of any working system of any organization – stay granted - ST/90/2008 - S/353/2008-WZB/C-I/(C.S.T.B.), - Dated:- 26-6-2008 - Ms. Jyoti Balasundaram, Vice-President and Shri A.K. Srivastava, Member (T) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... services in connection therewith, advisory services to substantial acquisition of share of listed companies, etc. It is the contention of the applicants that none of these advisory services are in the nature of advice relating to conceptualizing, devising, development, modification, rectification or upgradation of any working system of any organization which alone would fall within the scope of d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncluded in management consultancy services was scrutinized by the Department and, therefore, everything was within the knowledge of the Department and hence the applicants have not suppressed anything so as to invoke the extended period of limitation. For these reasons, waiver of pre-deposit of service tax and penalties is sought by the applicants. 3. The prayer is opposed by the ld. S.D.R., w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ces issued/raised by them to the Department so as to enable the Department to raise the demand within the statutory period of limitation. He submits that the extended period has, therefore, rightly been applied against the applicants. He, therefore, submits that the applicants have not been able to make out a case either on merits or on limitation for waiver, whereas the Department has made out a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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