TMI Blog2007 (11) TMI 290X X X X Extracts X X X X X X X X Extracts X X X X ..... tise and technical assistance from them - According to applicant, sale of know-how should not be treated as rendering of services- further applicant submitted that services though utilized in India by the appellant they were actually rendered outside India - findings of the Commissioner that the applicant was liable to pay service tax in the category of Consulting Engineering Services is, prima fa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rmed a demand of Rs. 1,12,62,240/- along with interest and imposed penalty under Section 76. He has relied on the clarification on the scope of service issued by CBEC vide their Circular F. No. B. 43/5/97-TRU, dated 2-7-1997. 3. According to the ld. Advocate for the appellant-applicant, sale of know-how should not be treated as rendering of services; such payments were made for transfer of know-h ..... X X X X Extracts X X X X X X X X Extracts X X X X
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