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TMI Blog2013 (4) TMI 627X X X X Extracts X X X X X X X X Extracts X X X X ..... or the Appellant : Shri S.R. Dixit, Advocate For the Respondent: Shri K. Sivakumar, A.R. JUDGEMENT Per : Mr. M.V. Ravindaran; This appeal is directed against the order in appeal No. Commr(A)/371/VDR-I/2011 dated 11.10.2011. 2. The facts of the case are that, it was noticed by the department that the appellant was providing Manpower Recruitment or Supply Agency Service and not paid service ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er Section 75 of the Finance Act, 1994 and for appropriation of Rs. 65,078/- already paid by the appellant and for imposition of penalties under Section 76 and 78 of the Finance Act, 1994. The adjudicating authority confirmed the demand of service tax Rs. 3,40,105/- and appropriate the said amount already paid by the appellant, ordered recovery of interest under Section 75 and appropriated Rs. 65, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... suance of show cause notice. It is his submission that the relevant period in the case is 16.6.2005 to 30.6.2009. It is his submission that the service tax liability on supply of Manpower was introduced in the statute from 16.6.2005 and there was confusion as to who has to discharge the service tax liability and the appellant being in rural area was not aware of nitty-gritty of law. It is his subm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd that the service tax liability on the Manpower Supply services was introduced in the statute on 16.6.2005 and it is also well-known that there were many decisions as who is liable to discharge service tax and on which amount. The definition of Manpower Supply service has under gone change twice. All these confusions may have created a situation wherein the assessee in this case may not be aware ..... X X X X Extracts X X X X X X X X Extracts X X X X
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