TMI Blog2018 (3) TMI 638X X X X Extracts X X X X X X X X Extracts X X X X ..... or the Appellant Shri K. Veerabhadra Reddy, JC (AR) for the Respondent ORDER Per Bench The appellants herein are engaged in providing training in software and systems. The department took the view that these services provided would attract levy of service tax under the category of Commercial Training and Coaching (CTC) and Franchisee Service. Show cause notice dated 6.9.2007 was issued f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lowed claim of the appellant for abatement of the cost of books supplied as course materials. The appellant is now in appeal only on the disallowance of abatement of the cost of books supplied by them. 2. Today, when the matter came up for hearing, ld. counsel Shri J. Shankar Raman places reliance on the Tribunal s decision in Cerebral Learning Solutions Pvt. Ltd. vs. Commissioner of Central Exci ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... raws our attention to para 7 and 8 of the impugned order to highlight that a lump sum is collected from the students indicating the total cost of the course materials as against the claim made by them in the pamphlet. The Commissioner has also found that the bills indicate only the coaching fees charged from the students and that there is no specific break-up in respect of cost of the books sold b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed copies of profit and loss account at the stage of adjudication and have also annexed them in page 62 of the appeal book which separately indicates the cost of books and materials. In the circumstances, we find that the ratio of Cerebral Learning Solutions Pvt. Ltd. (supra) will have to be applied to the present appeal and that notwithstanding Board s Circular dated 20.6.2003, the cost of the bo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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