TMI Blog2014 (11) TMI 756X X X X Extracts X X X X X X X X Extracts X X X X ..... d by the Management Consultancy Service, as there is no element of any consultancy with objective of management, rectification or improvement of the working system of an organization. The activity of the appellant therefore does not fall under Section 65(105)(r) read with Section 65(65). As such, the impugned order is not sustainable. The same is set aside - Decided in favour of assessee. - APPEAL NO. ST/101/2009-CU(DB) - FINAL ORDER NO. 52404/2014 - Dated:- 23-5-2014 - G. RAGHURAM AND RAKESH KUMAR, JJ. For The Appellant : Alok Arora For The Respondent : Pramod Kumar ORDER Rakesh Kumar, Technical Member The appellants are manufacturers of M.S. Ingots. During scrutiny of their balance sheet in the financial year 1999 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for the appellant, pleaded that in terms of Section 65(105)(r), service provided to a client by a Management Consultant in connection with the management of any organization, in any manner is taxable, that the term Management Consultant is defined under Section 65 (65) as, any person who is engaged in providing any service either directly or indirectly in connection with the management of any organization in any manner and includes any person who renders any advice, consultancy or technical assistance, relating to conceptualizing, devising, development, modification, rectification or upgradation of any working system of any organization that in the present case, the department has not specified as to which organization is the recipient of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ny advice, consultancy or technical assistance, relating to conceptualizing, devising, development, modification, rectification or upgradation of any working system of any organization. 8. In this case, the organization to whom Management Consultancy service is alleged to have been provided is not specified. Moreover, the service provided has to be in relation to the Management of an organization including advice, Consultancy or technical assistance for rectification or improvement of system of the organization. Mere helping a client in executing the export orders or in selecting granite blocks is not at all covered by the Management Consultancy Service, as there is no element of any consultancy with objective of management, rectificati ..... X X X X Extracts X X X X X X X X Extracts X X X X
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