TMI Blog2024 (3) TMI 693X X X X Extracts X X X X X X X X Extracts X X X X ..... ty to service tax - construction activities - main contractor was discharging Service Tax liability - Revenue is of the view that during the impugned period, sub-contractors are required to pay Service Tax in terms of Master Circular No. 96/7/2007-S.T. dated 23.08.2007 - Time limitation - HELD THAT:- Although in terms of the Master Circular No. 96/7/2007-S.T. dated 23.08.2007 the respondents were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Revenue. The same are dismissed. - HON BLE SHRI ASHOK JINDAL, MEMBER (JUDICIAL) And HON BLE SHRI K. ANPAZHAKAN, MEMBER (TECHNICAL) Shri S. Mukhopadhyay, Authorized Representative for the Appellant/Dept Shri Manish Rastogi, Advocate for the Respondents ORDER Order : [ Per Shri Ashok Jindal ] Both the appeals are having a common issue and therefore, both are disposed of by a common order. 2. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Aggrieved from the said orders, the Revenue is before us. 4. The Ld. Authorized Representative appearing on behalf of the appellant/Revenue submits that during the impugned period, the respondents were knowing that in terms of the Master Circular No. 96/7/2007-S.T. dated 23.08.2007, they were liable to pay Service Tax, being a sub-contractor, but were not paying Service Tax and thus Service Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h the facts placed before us, we find that although in terms of the Master Circular No. 96/7/2007-S.T. dated 23.08.2007 the respondents were liable to pay Service Tax being the sub-contractor, on the premise that the main contractor had discharged their Service Tax liability, the respondents did not pay Service Tax. The fact of non-payment of Service Tax had come to the knowledge of the Revenue in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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