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2013 (4) TMI 853

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....ctor, for the Appellant. Ms. D.M. Durando, Dy. Commr. (AR), for the Respondent. ORDER [Order per : S.S. Kang, Vice-President]. - The appellants filed this appeal against the impugned order passed by the Commissioner of Central Excise (Appeals), Mumbai. The appellants registered with the Revenue as an Advertising Agency. The present proceedings were initiated by issuing a show cause notice....

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....)  Sales Strategy development (iii)  Analysis and interpretation of NRS/IRS data (iv)  Presentation development on latest NRS data and (v)   Media Consultancy. 3. During the argument, the appellants admitted that the media consultancy is in respect of advertisement. 4. In respect of other activities, the contention is that the appellants are only c....

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....y sales strategy development is in respect of the sales of the goods. Other activities such as analysis and interpretation of NRS/IRS data are undertaken and prepared by two industry bodies, which result in research data for assisting in decision making by the clients of the appellants. Further we find that the Revenue is relying upon the statement of the Director of the firm whereby he explained ....

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....product awareness and their general experience of the product. The contention of the appellants is that as the appellants were paying service tax regularly on advertising consultancy service, the appellants were under the bona fide belief that the activities were not covered under the scope of Advertising Agency or Advertising Consultant. Therefore, under the bona fide belief the appellants have n....