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2014 (10) TMI 769

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....hri R. Gurunathan, AR, for the Respondent. ORDER Appellant made the following submissions in respect of demand for service tax amounting to Rs. 23,28,393/- for the period from 1-7-2003 to 3-9-2010. The demand has been made on the ground that the appellants were providing manpower recruitment and supply service and commercial training and coaching service. *       T....

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.... make available qualified nurses outside India to the recipient of service in the foreign country. The service was effectively rendered only when the appellant made available qualified nurses to the company in USA. *       The appellant is bound to refund the amount paid by the foreign company to the appellant in the event the nurse does not take employment in the ho....

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....road or in the event of their failing the test, the appellants do not get any payment for the same. In such an event the nurses are sent back. The demand has been made in respect of remuneration received from abroad for sending nurses after training on the ground that it amounts to manpower recruitment and supply service and the benefit of treatment of service as export of service has been denied.....