2005 (4) TMI 364

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....known as 'Angadia.' Hence these appeals are disposed of by this common order. 2. The ld. Advocates for the appellants fairly concede that their clients indulge in providing services for transport of valuable documents, like diamond packets, and other articles of gold and silver from various branches to their H.O. and from H.O. to branches and inter branch transports are so effected. Door to door service is also provided whenever and wherever required. The ld. Advocates do not contest the registration and or payment of Service Tax on remunerations for these services. The appellants are aggrieved only as regards the Service Tax levied on the commissions retained, on facility provided, by them for transfer of money. Under this facility....

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....s no doubt, in fact no contest by the appellants, that they are covered under the levy of Service Tax as a courier agency, in the case of documents, diamonds and other goods/articles on Indian currency transfers, levy cannot be attracted as : (i)      there is no transportation of the currency which was in fact deposited at the branch and thereafter same is not physically transported to the delivery point. What moves is only instructions transmissions by various methods of communication and not currency. (ii)     The ld. SDR has relied upon certain passages in the order impugned which indicate that certain cash and diamonds were looted from the possession of an employee one of the appellant....