2013 (4) TMI 856

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....o, Deputy Commissioner (AR), for the Respondent. ORDER [Order per : S.K. Gaule, Member (T)]. - Heard both sides. 2. The applicant filed this appeal against Order-in-Appeal Nos. 22-25/STC-I/SKS/12-13, dated 23-7-2012 whereby the Commissioner confirmed the demand of Service Tax of ₹ 80,275/-. 3. Briefly stated the facts of the case are that the appellant is holder of Service Tax ....

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....ided by the appellant as an Advertising Agency in relation to advertisements to their customers. Accordingly proceedings were initiated against the appellant by issue of four show cause notices for recovery of the Service Tax on the gross amount received from their clients for recovery of the Service Tax by invoking the larger period of limitation and also proposing imposition of penalty. The Comm....

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....ods are exempted vide the aforesaid notification and the learned Commissioner appreciated the fact and extended the benefit to them for the period subsequent to June, 2003. He however confirmed the demand for the period prior to issuance of the notification. The contention is that they were under the bona fide belief that the value of the printing of envelopes, etc., done by the sub-contractor is ....

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....e period prior to that is not eligible for exclusion of the value of the materials used in printing, etc. Therefore, the demand is rightly made. 6. We have carefully considered the submissions and perused the records. Undisputedly the appellants were paying Service Tax on the conceptualization and designing of advertising and they were not including the value of the material and only printin....