TMI Blog2008 (8) TMI 157X X X X Extracts X X X X X X X X Extracts X X X X ..... t. ORDER 1. Common issues involved in both the appeals and, therefore, both are being taken up together for disposal. 2. After hearing both the sides and on perusal of the records, it is seen that the dispute relates to the service tax liability on the respondent with reference to the service from their Foreign Agents prior to 1-1-2005. The Commissioner (Appeals) allowed the appeal of the respo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or from outside India, who does not have any office in India, having been specified as 'taxable service' with effect from 1-1-2005, under Notification No 36/2004, recipient of such service could not be held liable for paying service tax prior to 1-1-2005 notwithstanding the amendment in rule 2(1)(d) of the Service Tax Rules under Notification No.12/2002. We thus concur in the view expressed in th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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