2017 (3) TMI 865

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....f facts of the case are that the department had taken the view that appellant should have discharged service tax liability under reverse charge basis as per Rule 2 (1)(d)(iv) of Service Tax Rules, 1994, under Franchise Service for the fees paid to M/s. Meridian S.A. France, based on the agreement entered with them.  In the adjudication proceedings, the original authority confirmed the demand ....

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....y sanctioned refund of Rs. 20,69,124/- only.  Department preferred an appeal against this sanction order to the ld. Commissioner (Appeals), who vide the impugned order dated 27.10.2015 allowed the appeal of the department, interalia, which is reproduced as follows:- "6 (iv)    The facts not in dispute in the present case is that the service provider namely M/s. Meridian S.A. F....