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<h1>Explanation to Section 65(19) Finance Act operates prospectively. Appeal allowed, impugned order set aside.</h1> <h3>MS. ASSOCIATES Versus COMMISSIONER OF SERVICE TAX, NEW DELHI</h3> MS. ASSOCIATES Versus COMMISSIONER OF SERVICE TAX, NEW DELHI - 2013 (32) S.T.R. 727 (Tri. - Del.) The Appellate Tribunal CESTAT NEW DELHI ruled that the explanation to Section 65(19) of the Finance Act, 1994 operates prospectively. The Tribunal considered this aspect in detail and found that it cannot create a liability retrospectively. The appeal was allowed, setting aside the impugned order.