2014 (8) TMI 626

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....llant. Shri R.K. Singla, Commissioner (AR), for the Respondent. ORDER Heard both sides extensively on the stay petition. 2. The appellant is a subsidiary of Sun, USA. The appellants along with Authorized Sun Education Centre (ASEC partners) are involved in facilitating conduct of online examination for awarding various certificates by Sun, USA. The online examination and evaluatio....

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....hould be treated as rendering of services in relation to education and that they are eligible for the benefit of exemption Notification No. 14/2004-S.T., dated 10-9-2004. 3.2 He further submits that there was audit of the appellant's activities by the department during 2005 and audit notes were issued in April 2006 and in pursuance to the said audit notes, discussion meeting was held with ....

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.... training is given by the appellants to treat their activities as part of any educational programme. Further, he submits that these grounds have not been taken before the Commissioner. 5.1 We have carefully considered the submissions from both sides and perused the records. The prospective candidates do not, prima facie, have a relationship of student-teacher in the programme leading to is....

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.... very same activities in 2009 by the Commissioner, the issue of show-cause notice for the period from October 2004 to March 2009 invoking extended period of limitation may not be justified. 5.3 No financial hardship has been pleaded before us. 6. In view of the above, we deem it appropriate to direct the appellant to deposit Rs. 1 crore (Rupees One crore only) within 6 weeks from t....