TMI Blog2014 (11) TMI 833X X X X Extracts X X X X X X X X Extracts X X X X ..... gistration for each Division/Zone for the purpose of discharging service tax liability. There is no dispute on the fact that BSNL has one single PAN number and one Profit and Loss/Balance Sheet. The definition "to any person" defined in the Section 105 (zzzx) of Finance Act, 1994 refers to a separate legal entity". The citation relied upon by the appellant in the case of Precot Mills Ltd. Vs CCE T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; 19,18,95,836/- along with interest and penalties. 2. The brief facts of the case are that the appellants are PSU engaged in providing Telecom Services to the subscribers and interconnection service to other Telecom operators and discharging service tax. The SCN dt. 18.10.12 was issued demanding service tax on the interconnection service rendered to their own landline of BSNL for the period 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ded in the Finance Act, 1994, a person is a legal entity. They relied upon the following case laws :- (i) Precot Mills Ltd. Vs CCE Tirupati - 2006 (2) STR 495 (Tri.-Bang.) (ii) Senior Terminal Manager, IOCL- 2009 (13) STR 287 (Tri.-Chennai) (iii) Indian Oil Corporation Ltd. Vs CCE Patna 2007 (8) ELT 527 (Tri.-Kolkata) He submits that there is no service tax levi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... connection Seeker have been defined and the appellant provided interconnectivity service to BSNL Landline Division. 5. Heard both sides. The adjudicating authority has demanded service tax on BSNL Cellular Division on the Inter-connect usage charges for BSNL Landline Division. BSNL is a PSU entity who has taken separate registration for each Division/Zone for the purpose of discharging service ..... X X X X Extracts X X X X X X X X Extracts X X X X
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