2007 (2) TMI 114

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....ls arise out of the order of the Commissioner of Central Excise who has confirmed service tax demands of Rs. 27,71,955/- raised in show cause notice dated 28-10- 2004 and Rs. 2,38,09,000/- raised in show cause notice dated 20-5-2005 on ac count of services availed by them after 16-8-2001 under the proviso to Section 73(1) of the Finance Act, 1994 read with Rule 6 of the Service Tax Rules, 1994, to....

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....by the appellants, holding technical know-how as a service falling under the category of consulting engineer services. 2. We have heard both sides. 3. As regards the first demand, we find that the appellants had disputed that the German firms and the US firms were engineering firms, in their reply dated 3-11-2004 to the show cause notice dated 28-10-2004 and had in fact denied the stand of t....

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....ffice in India, such service was notified in the Official Gazette, in exercise of the powers conferred by sub-section (2) of Section 68 of the Finance Act, 1994 only on 31-12-2004 with the issue of Notification 36/2004-S.T. which came into force on 1-1-2005, while the period in the present case is prior to such date, and service tax is therefore not leviable for the period prior to 1-1-2005, in th....