2011 (12) TMI 397

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....the case are not in dispute. The appellant-bank has advanced loan to the farmers who have bought tractors from M/s TAFE and the amount has been paid to M/s. TAFE against such purchase. In respect of the amount received for the service rendered for sanction and disbursement of the loan, the appellants have paid the service tax. The dispute is in relation to some amount they have received from M/ s.....

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....issioner. However, there is no satisfactory reason given therein to reverse the finding of the original authority in regard to extending the benefit under Section 80 to the appellants. There is also no finding of any suppression, fraud etc. and the fact that the appellants have retained some amount out of the loan disbursed to M/s. TAPE does not alter the character of the amount being a payment by....