2013 (10) TMI 585

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....cates For the Respondent : Shri Pramod Kumar, A.R.(Jt.CDR) ORDER Per Justice G. Raghuram: Service tax of Rs.6.5 crores (approx.) is assessed by the adjudication order dated 31.8.2012 under three heads: (a) Rs.4.39 crores (approx.) under a reverse charge mechanism for having received 'manpower recruitment or supply agency' service from BMW U.K. and Germany by way of deputation of technical an....

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....he petitioner claims immunity under the provisions of Export of Service Rules, 2005 relying on the judgment of the Larger Bench in Paul Merchants Ltd. vs. C.C.E., Chandigarh 2012 TIOL 1877 CESTAT DEL. In view of the decision in Paul Merchants Ltd., prima facie the issue is in favour of the petitioner/assessee in respect of Rs.16,65,550/- and Rs.1,74,76,381/- . 3. The adjudication order also appea....