TMI Blog2014 (7) TMI 822X X X X Extracts X X X X X X X X Extracts X X X X ..... activity became taxable. As such, the service cannot be held to have been rendered at the time when it became taxable - the fact that the payment was made one time in the case of Denso Haryana Pvt. Ltd. case whereas royalty is being paid on the yearly basis in the present case cannot be adopted as a criteria to distinguish the ratio of law declared in the case of Denso Haryana Pvt. Ltd. Admittedly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on 77 of Finance Act, 1994. 2. After hearing both the sides, we find that the said tax stand confirmed proceeded against the applicant for the period 27th September 2006 to 26th November 2007 on the ground that they have received IPR services from a U.S. firm and they are required to discharge their duty liability on reverse charged basis. 3. The appellant s contention is that such services ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Haryana Pvt. Ltd. v. CCE, Delhi-III (supra), whereas it is IPR service in the present case does not appeal to us. It is the ratio of law which is relevant. Further the fact that the payment was made one time in the case of Denso Haryana Pvt. Ltd. case whereas royalty is being paid on the yearly basis in the present case cannot be adopted as a criteria to distinguish the ratio of law declared in t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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