TMI Blog2008 (8) TMI 69X X X X Extracts X X X X X X X X Extracts X X X X ..... rm ‘customer’ will include such merchant establishments - from 01.05.06 the services rendered by the Bank to both the card holders and the merchant establishments have been specifically and comprehensively, brought under ST – stay granted - ST/462/2008 - ST/331/2008-(PB) - Dated:- 14-8-2008 - Justice S.N. Jha, President and Shri M. Veeraiyan, Member (Technical) Shri V. Laxmikumaran, Advocat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... part of the amount collected from the card holders towards whatever services rendered by them to the merchant establishments. 4. The Department has held that not only the transaction between the Banks and card holders are covered under Banking and other financial services, particularly, as credit card services, but also the transactions between the Bank and various establishments, are also c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of limitation, even if it is held that during the said period the services can be treated as credit card services, no mala fide on the part of the appellant can be attributed as the Department itself was of similar views during the relevant period. He submits that the Circular of 9th July, 2001 issued at the time of introduction of Service Tax on banking and financial services has given the scop ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the invoking of extended period of limitation, she submits that prior to 10.09.2004 the extended period can be invoked in every case of escape of assessment and substantial period of the demand relates to period prior to 10.09.2004. She seeks pre-deposit of substantial amount to safeguard the interest of the Revenue. 7.1. We have carefully considered the submissions of both sides. We are of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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