TMI Blog2017 (4) TMI 861X X X X Extracts X X X X X X X X Extracts X X X X ..... npower recruitment service - Held that: - The law was amended and it is only from 16th June, 2005 that manpower recruitment or supply to third parties is brought within the net of the tax - the assessee was held liable to pay service tax with effect from 16th June, 2005 under that category. Intellectual property service - Business support service - Held that: - the respondent assessee has the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lted in a demand in the sum of ₹ 4,99,07,210/- with interest and penalty under Section 78 of the Finance Act, 1994. 4 As far as computer training services are concerned, in paragraph 3 of the impugned order, the Tribunal traces the history of how that service was brought within the net of the tax. The Appellant before the Tribunal namely the respondent assessee urged that there was a no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld that in the facts and circumstances, the demand within the limitation and normal period deserves to be confirmed. The demand beyond the normal period cannot be confirmed and no suppression is proved particularly in the light of the factual finding peculiar to the assessee. 6 Even with regard to manpower recruitment, the assessee was only providing manpower to software companies when required ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h was allowed to be used by their clients. That is why the demand within the limitation period was confirmed and equally the penalties. Thus, the peculiar facts pertaining to the respondent assessee led to the partial confirmation of the demand. 8 As far as the business support service is concerned, even on that count the demand is confirmed as above. 9 Resultantly, we find that the Tribunal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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