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TMI Blog2009 (2) TMI 180X X X X Extracts X X X X X X X X Extracts X X X X ..... endered by the applicant, whether the service provided by them is a sovereign function of a country or not, is not clear and debatable. The circular which has been relied on would also, prima facie, not in favour of the applicant - Thus the appellant has not made out prima facie case for complete waiver of pre-deposit of the amount. Accordingly, we direct the applicant to deposit an amount of Rs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er day from the due date under Section 76 of the Finance Act, 1994; (v) Penalty of Rs. 1,82,75,529/- under Section 78 of Finance Act, 1994; and (vi) Penalty of Rs. 1000/- under Section 77 of Finance Act, 1994. 2. Heard both the sides in the matter and perused the records. 3. It is the submission of the learned Consultant that the amount confirmed by the lower authority is in respect of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... On a careful consideration of the matter, we find that the issue with regard to service rendered by the applicant, whether the service provided by them is a sovereign function of a country or not, is not clear and debatable. The circular which has been relied on would also, prima facie, not in favour of the applicant. As regards the time bar, we find that the said letter just mentions the informat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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