2013 (10) TMI 690

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....rintendent (AR) ORDER Per Mathew John; 1. Applicant had received services of technical know-how from their parent company, M/s. NSK, Japan during the years 2004-05 and 2005-06 Payments for these years were provided in their books of accounts during the respective years but were actually paid during September 06 i.e. after 18.4.2006 when section 66A was introduced in Finance Act, 1994. Rev....

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.... were received prior to that date though payment was made after the said date. He submits that during that particular period, there was no specific rule as to what will be the crucial date for determining the tax liability but the Tribunal has always held that date of receipt of service is relevant and not the date of payment of consideration. Once that criteria is adopted, there is no tax liabili....