TMI Blog2015 (12) TMI 547X X X X Extracts X X X X X X X X Extracts X X X X ..... r the substantial amount and a small amount towards "Manpower Recruitment Service & Supply Agency Service". We find that the services rendered by the employees of the appellant are in respect of running the business of the group companies efficiently. The top most level of the employees to the middle management and lower management levels of the employees are rendering the services which could be in support of the business of the group companies as also the advisory function in respect of various departments. In our view, the lower authorities, in this case has correctly classified the services rendered by the employees of the appellant under ‘Business Support Service' and ‘Management Consultancy Services'. We do not find any reason to inte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng in the audit report hence show-cause notice was issued to the appellant for demand of service tax liability of ₹ 16,81,858/-, the interest thereon and the show-cause notice also sought to impose penalties. Appellant contested the show-cause notice on limitation as well as on merits. Adjudicating authority did not agree with the contentions raised by the appellant and confirmed the demands with interest and also imposed penalties. On an appeal, the first appellate authority also concurred with the view of the Adjudicating authority and rejected the appeal filed before him. 3. Ld. CA would take us through the entire case record. It is his submission that the appellant assessee had recovered certain amount but registered the same u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the fact that appellant's employees are rendering various services to the group companies; appellant is also recovering some amount from the group companies and recording the same as receipts under salary and wages. It is to be noted that the show-cause notice in the case in hand seeks to demand the service tax liability under Business Support Service and Management Consultancy Services for the substantial amount and a small amount towards Manpower Recruitment Service Supply Agency Service . We find that the services rendered by the employees of the appellant are in respect of running the business of the group companies efficiently. The top most level of the employees to the middle management and lower management levels of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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