TMI Blog2017 (1) TMI 1463X X X X Extracts X X X X X X X X Extracts X X X X ..... application to the facts of the present case regarding promotion and marketing of service. Though, there is no written agreement, it is apparent that the activity of the appellant promoted the services rendered by their sister concern. This much is clear from the nature of consideration received by the appellant, which is categorized as liaisoning charges in P & L account - demand upheld. Exte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... liable to Central Excise Duty. The dispute in the present case relates to their activity of acting as intermediary for their sister concern Hira Industries Ltd., in connection with crushing up ore of another person. They had one transaction as intermediary in the year 2005 and received consideration for the same from their sister concern. 2. The Revenue entertained a view that the said activit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ered as promotion or marketing of service, provided by the client. They have not involved in such activity on a regular basis. The tax liability now is with reference to a single activity in 2005. The receipt of consideration on such activity has been captured in all their records and reflected in the balance sheet. The ld. Counsel contested the demand on merit and time bar. Regarding time bar he ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r clarified by the competent authority. 5. We have heard both the sides and perused the appeal records. We find that the impugned order confirmed the service tax liability on the activity of the appellant as intermediary under the category of sub-clause (ii) and (iv) of [definition of] BAS. These provisions deal with promotion or marketing of services provided by the client and procurement of g ..... X X X X Extracts X X X X X X X X Extracts X X X X
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