2004 (7) TMI 2

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....(Appeals) whereunder the appeal of the appellants against the order-in-original passed by the Assistant Commissioner was rejected. Vide the order of the Assistant Collector, the appellants were directed to pay an amount of Rs. 4,70,707/- towards service tax liability under Section 68 of the Finance Act, 1994. 2. Heard both sides. 3. The appellants pray that they have strong prima facie case ....

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....er is not covered under Section 73 of the Act. 4. I have considered the submission and I note that reference to Section 73 is totally unjustified. Here the liability is cast on the person who is service availer. Since this is a special deeming provision in respect of availer of the services of Goods Transport operators and the recovery of Service Tax has been authorised (validated) in terms of ....