2012 (9) TMI 21

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....spondent. [Judgment per : N. Kumar, J.]. -  The question that arises for consideration in this appeal is : When the service provider is outside the country who has no fixed establishment or permanent address in the country, the service rendered by him inside the country is to be taxed at whose hands? 2. Prior to 18-4-2006 i.e., amendment to Section 66A of the Finance Act, 1994 (herei....