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2011 (4) TMI 244

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....R: M.VEERAIYAN   This is an appeal against the order of the Commissioner No01/Commr/ST/2007 dated 14.03.07 by which demand of service tax amounting to 82,25,013/- alongwith interest stands confirmed and penalty under section 76, 77 and 78 of the Finance Act, 1994 stands imposed.   2. Heard both sides.   3. The relevant facts in brief are that the appellants is a company reg....

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.... on amounts received as grant in aid from different government sources. No service provider client relationship exists between the appellants and the government department. The work undertaken at the instance government departmenst cannot be treated as taxable service. The grant in aid paid by the Government cannot be treated as charges for the services rendered by the appellants to the government....

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....fore us. Further, as submitted by the learned Advocate, we find that correspondences exchanged between the department and the appellants which are sought to be relied upon before us have not been considered by the commissioner. Further, the decision of the Tribunal dated 16.8.10 was not available when the matter was considered by the commissioner. It was also claimed that the bifurcation of taxabl....