2010 (12) TMI 943

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....Member. - Both sides are in dispute on the issue whether the commission paid by the appellant to the foreign service provider during the period 9.7.2004 to 10.1.2006 shall be taxable in absence of taxing provision which came later into Statute Book by Finance Act, 2006. 2. Learned Counsel Shri Bajaj appearing on behalf of appellant submits that the sale proceeds were realised as evident from....

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.... to support his contention that the appellant shall not be liable for the disputed period in absence of taxing provision. His further submission was that when section 66A of Finance Act, 1994 was not in force for the period 9.7.2004 to 10.1.2006, the machinery provision disabled Revenue to realise service tax from the appellant in respect of the aforesaid service received by the appellant which wa....