2014 (5) TMI 260

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....Shri Amresh Jain, AR PER: G. Raghuram, J. 1. This Miscellaneous Application seeks leave to raise additional grounds on substantially legal issues, in the appeal. In the circumstances, this application is ordered. 2. The Commissioner Central Excise, Jaipur I, by the adjudication order dated 28.02.2013 confirmed service tax liability of Rs. 11,19,46,883/- besides penalty equivalent to the serv....

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....s also contended that the legislative fiction incorporated by the provisions of Section 66 A (2) is only to the effect that service provided by one permanent establishment of an overseas corporate entity to another permanent establishment of such corporate entity located in India is to be treated as service by one person to another so as to invite the levy of tax under reverse charge mechanism, un....