2014 (1) TMI 713

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....spondent. ORDER Heard both sides extensively on the stay petition. 2. The applicant has entered into agreement referred to as 'franchisee agreement' with BSNL in respect of cell phone services rendered by BSNL. They were receiving SIM cards/recharge coupons with specified face value; while delivering such SIM cards/recharge coupons, BSNL has undisputedly paid Service Tax on the face value.....

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.....g. the order in the case of Devangi Communications v. Commissioner, Mysore reported in 2010 (19) S.T.R. 779 on identical issue involving BSNL. 3.2 Referring to paragraph 9 of the Circular F. No. 334/3/2011-TRU, dated 28-2-2011, he submits that the Valuation Rules for Service Tax stands amended to treat the gross amount paid by the subscribers to be the value for taxable purposes in respect ....