TaxTMI 
TaxTMI 
2015 (12) TMI 491
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....e department for service tax purposes and the registration number is AAECS3306EST001. They have obtained External Commercial Borrowings (ECB) from financial institutions based abroad and paid fees for arranging/obtaining ECB loans. 2. The brief facts of the case are that the appellant company availed ECB loan of US $ 30 millions from ICICI Bank Ltd, Vadhodara/Bangalore, who served as agent and process their barrowing for which they were paying US $ 3,00,000, in INR Rs. 1,38,12,000/- on 29/09.2006 as processing fee and ICICI Bank Ltd. paid service tax of Rs. 16,90,589/- for the same. The appellants also paid US$ 12,00,000/-, in INR Rs. 5,52,48,000/- on 29.09.2006 to ICICI Bank Ltd., Singapore Branch as arranger fees in terms of arrangement ....
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....rnal commercial borrowing (ECB) of US$ 30 million from ICICI Bank Ltd., Singapore Branch for modernization and expansion of their unit and for this purpose they entered into agreement with ICICI Bank Ltd., Singapore for availing ECB of US$ 30 million. ICICI Bank LTd., Bangalore, India, served as agent and process their borrowings for which they were paid an amount of US $ 3,00,000 in INR Rs. 1,38,12,000/- on 29.09.2006. For the said loan processing fee, the agents have paid service tax @ 12.24% amounted to Rs. 16,90,589/-. They have also paid US$ 12,00,000/- on 29.09.2006 to ICICI Bank Ltd., Singapore Branch as arranger fees. The appellant being the recipient of the service, the entire service tax amount of Rs. 66,29,760/- was paid by them ....
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....yment of any interest. He further submitted that but for the investigation undertaken by the officers, the fact of non-payment of service tax by suppressing the fact by the assessee would not have come to light and would have remind un-noticed, resulting in revenue loss to the Government. He reiterated the findings of the adjudicating authority. 5. Heard both sides in detail and on perusal of the documents, we find that the appellants having come to know about their liability to pay service tax as the recipient of the service, immediately paid the entire amount of service tax along with education cess amounting to Rs. 67,62,355/-. We also find that the appellant have remitted the interest amount of Rs. 5,73,225/- on 25.11.2008, for delayed....