2013 (10) TMI 1216

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..... nchisee service is based on the agreement - Prima facie, the tax is payable as per the agreement between the applicant and other persons - The submission of the learned counsel on the limitation aspect would be examined at the time of appeal hearing - applicant was directed to deposit a sum - Upon such deposit, pre-deposit of the balance dues stand waived and recovery thereof stayed during the pen .....

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..... rned counsel submits that, prima facie, the demand was made on the basis of the agreement but the real state of affairs would reveal that the services fall under the category of IPR Service. He also submits that the demand is barred by limitation. The learned AR reiterates the findings of the Commissioner (Appeals). He submits that the demand of tax on the franchisee service is based on the agreem .....

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