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2011 (1) TMI 1066 - AT - Service TaxWaiver of pre-deposit and stay of recovery - management consultancy service - secondment charges paid in foreign currency as consideration for management consultancy service was not disclosed to the department - appellant has submitted that, even if it be assumed that a taxable service was provided by M/s. British Gas to MGL, any amount of service tax could not be demanded from MGL for the period of dispute inasmuch as this period is prior to 18-4-2006, the date on which Section 66A was inserted also an Indian recipient of a taxable service provided by a non-resident person having no office in India cannot be deemed to be a service provider for purposes of payment of service tax for any period prior to 18-4-2006 - Held that:- Appellant has only a debatable case and has not established a foolproof case for complete waiver of pre-deposit , appellant has to make pre-deposit of a reasonable part of the amount of service tax for purposes of Section 35F of the Central Excise Act
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