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2018 (2) TMI 18 - AT - Service TaxIntellectual Property Service - The department was of the view that since the Intellectual Property Service came within the tax net with effect from 10.09.2004, the respondents were liable to pay service tax as a service recipient of the foreign company under the reverse charge mechanism - Held that: - an identical issue was considered by the Tribunal in the case of Commissioner of Service Tax, Delhi-III Vs Denso Haryana Pvt. Ltd [2015 (11) TMI 235 - CESTAT NEW DELHI] where the Tribunal has observed that the agreement was executed before 10.09.2004 and there cannot be any continuous supply of service so as to make the same taxable after 10.09.2004 - however, prior to 18.04.2006, the demand unsustainable as per decision laid down in the case of Indian National Shipowners Association [2008 (12) TMI 41 - BOMBAY HIGH COURT] - appeal dismissed - decided against Revenue.
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