2013 (1) TMI 603

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....s stay petition is filed for the waiver of pre-deposit of service tax liability of Rs.2,65,185/-, interest thereof and various penalties under various sections.  2. The above said amounts have been confirmed by the adjudicating authority and upheld by the first appellate authority on the ground that the appellants had rendered the services under business auxiliary services and not discharg....

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....ested the issue on merits, as services would not fall under the category of business auxiliary services and would fall under the category of business support services and during the relevant period business support service was not in statute.  He also submits that they had taken the issue of limitation before both the lower authorities.  It is his submission that the adjudicating authori....

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....ower authorities that they were having a bonafide belief that these services would fall under business support services and not under business auxiliary services.  We find that the adjudicating authority has not recorded any reasoning for rejecting the claim of the appellant as regards the limitation and the first appellate authority has not even recorded a single sentence on the question of ....