2013 (11) TMI 43

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....; This is an Application seeking waiver of predeposit of Service Tax of Rs.1,01,56,991/- and equal amount of penalty imposed under Section 78 of the Finance Act, 1994 and penalties under various provisions of the said Act. 2. At the outset, ld. Chartered Accountant for the Applicant has submitted that by an agreement with M/s. TELCO (now M/s. Tata Motors) dated 21.11.1984, they undertook transpo....

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.... cannot come under 'Manpower Recruitment or Supply Agency Services' as the payments were made on the basis of distance and not on person-wise, so as to attract levy under 'Manpower Supply Service'. 3. Ld. AR for the Revenue has reiterated the findings of the ld. Commissioner. 4. We have considered the rival submissions. Prima facie, we find that the Applicant are engaged in transporting/transfer....