2013 (10) TMI 531

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....nt : Shri Govind Dixit, A.R ORDER Per Justice G. Raghuram: The assessee has preferred this appeal against the adjudication order dated 31.12.2012 whereby service tax of Rs. 56,74,946/- has been for having provided the taxable - 'Sale of Space or time for Advertisement' Service, during 01.05.2006 to 31.03.2011. As apparent from the show cause notice; the assessee's response thereto; and th....

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....e was no wilful suppression or non remittance of tax with an intent to evade remittance of tax by contravention of the provisions of the Act. It was also contended that in any event the issue would be Revenue neutral, since even if service tax was paid the service recipient could have availed the benefit of input credit. 2. At the present stage we are not inclined to go into the issue of limita....

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....x to the extent advertisements by the assessee were in respect of spaces not owned by the Municipal Corporation, would not be liable to service tax. 4. Neither the adjudication order nor the show cause notice clearly indicates the proportion between private spaces on which advertisements were made by the assessee and the spaces belonging to the Agra Municipal Corporation. It was however contend....