2016 (10) TMI 460

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....sent case are that the appellant is a partnership firm and has entered into an agreement with Citi Bank for providing various services which are listed in schedule A of the said agreement which is on record. The services rendered by the appellant are in the nature of facilitating certain activities of the Bank as contained in schedule A of the agreement. The appellant has to bill the Bank for the services rendered as per schedule B to the agreement as stated in para 4 of the agreement under the heading computation and billing . As per the schedule B the appellant is entitled to a share of the charges collected by them as stipulated from time to time. The nature of the services envisaged by the agreement would show that the appellant was act....

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....'ble High Court of Kerala and the High Court vide its order dated 23.06.2009 held that the appellant is not entitled for exemption under Clause (e) of the Notification 25/2004-ST and thereby remanded the matter with a direction to the Tribunal to consider the Clause (d) of the said Notification. Aggrieved by the order of the High Court, appellant filed an appeal before the Hon'ble Supreme Court of India and the Hon'ble Supreme Court vide order dated 19.02.2016 set aside the portion of the order of the High Court and remanded the matter back to the Tribunal with a open remand to consider both Clause (d) and (e) of the Notification 25/2004-ST. 2. Heard both the parties and perused the records. 3. Learned counsel for the appellant submit....