TMI Blog2018 (9) TMI 1983X X X X Extracts X X X X X X X X Extracts X X X X ..... No. 1,2 for the RESPONDENT(s) No. 1,2,3 ORAL ORDER (PER : HONOURABLE MR.JUSTICE ANANT S. DAVE) 1. Heard Mr.Mihir Joshi, learned Senior Counsel appearing for the petitioners. 2. At the outset, our attention is invited to show cause notice dated 10.11.2017 issued by respondent no.3 seeking reasons why the amount of Rs. 62,51,39,050/- along with permissible interest and penalty should not be rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Rule 6A of the Service Tax Rules, 1994 (hereinafter referred to as "STR") read with the provisions of Section 65B(44) of the Act, the consulting engineering services rendered outside India by the Petition No.1 to any other subsidiary of Linde AG or holding company would qualify as 'Export of Services' as contended by the Petitioner, or Exempted Service under Rule 2 (e) of the Cenvat Rul ..... X X X X Extracts X X X X X X X X Extracts X X X X
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