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2004 (8) TMI 715 - Commissioner - Service TaxExtract: .......n, the penal action would also not survive both on merits and also on account of limitation. 30. I conclude by holding that the activity of the Appellant would correctly come only under the purview of Business Auxiliary Service and not as an Advertising Agency. Hence, the impugned order is set aside and Appeal allowed. 31. Appeal allowed.
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