TMI Blog2014 (7) TMI 120X X X X Extracts X X X X X X X X Extracts X X X X ..... to the overseas entity which is in the business of money transfers - Commissioner deleted penalty u/s 76 - Held that:- There is no dispute that as a consequence of the ratio discernable from the judgement of the Larger Bench in Paul Merchant Ltd. principal agents and sub-agents of M/s Western Union Ltd. and similarly circumstanced foreign Money Transfer entities are not liable to service tax unde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... i Atul Khullar, Advocate, Shri Sudhir Malhotra, Advocate, Shri Rakesh Chitkara, Advocate For the Respondent : Shri Amresh Jain, D.R. JUDGEMENT Per Justice G. Raghuram : Heard ld. Counsels for the several appellants and Shri Jain ld., DR for the respondent/Revenue. 2. The appellants herein (except the appellant in ST/206/2011) are either principal agents or sub-agents of over ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not be imposed. Service Tax Appeal No. 206/2010 is by the principal Indian agent M/s Western Union Network Ltd. 4. As all appeals involve identical issues of fact and law, these are disposed of by this common order, after hearing the ld. Counsel of the assessees and ld. DR for the respondent/Revenue. 5. A conflict of opinion between two Members who recorded the initial judgement was referre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions of the Export of Service Rules, 2005. 8. There is no dispute before us, that as a consequence of the ratio discernable from the judgement of the Larger Bench in Paul Merchant Ltd. principal agents and sub-agents of M/s Western Union Ltd. and similarly circumstanced foreign Money Transfer entities are not liable to service tax under provisions of the Act; since the services provided by thes ..... X X X X Extracts X X X X X X X X Extracts X X X X
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