2013 (3) TMI 37

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....ember (J)]. - This application filed by the appellant seeks waiver and stay in respect of service tax (including education cesses) of Rs. 92,37,339/- demanded from them under the head "Manpower Recruitment and Supply Agency Services" for the period from 1-5-2006 to 30-9-2009, interest thereon and the penalties imposed on the appellant under various provisions of the Finance Act, 1994. On a perusal....

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....h was rendered in the present appellant's own case [2011 (23) S.T.R. 132 (Tri. - Bang.)]. He has claimed prima facie case on merits by submitting that the activities in question cannot be brought within the ambit of the definition of "Manpower Recruitment or Supply Agency" as amended with effect from 1-5-2006. The learned counsel has also contested the demand on the ground of limitation. Contextua....

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.... Agency' as amended w.e.f. 1-5-2006. The circular relied on by the learned counsel is of no relevance inasmuch as the question discussed therein was whether an activity which would fall within the scope of the above definition w.e.f. 1-5-2006 could also be held taxable prior to that date. The decision cited by the learned counsel is also prima facie inapplicable inasmuch as that was a decision tou....