2009 (2) TMI 716

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....es, for the Appellant. Shri V.P.C. Rao, SDR, for the Respondent. ORDER In this case, the applicants had already discharged their service tax liability by availing the service tax credit earned on input services. In spite of the above fact, the Department is of the view that the applicants ought to have restricted the payment through credit to only 20% of the Service Tax on output service.....

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....rior period viz. April, 2006 to March, 2007, there would not be any liability at all on the applicants to pay service tax on their activities. When such a view is taken, then there is no question of any demand at all. Further, it was argued that services rendered to Special Economic Zone would amount to 'export' and there is a clear distinction between the exempted services and export services. ....