2017 (9) TMI 91

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....ant. Shri Ranjan Khanna, Authorized Representative (DR) - for the Respondent. ORDER Per: B. Ravichandran The appeal is against order dated 02/03/2012 of Commissioner (Appeals - I), Jaipur. The appellants are engaged in the manufacture of electrical goods and are involved in export of the same. For procuring orders for such export, the appellants availed the services of commission agent....

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....liability on the ground that the services are rendered outside India and consumption of services in India is not a taxable event. The demand is also contested on limitation. It is submitted that the liability of service tax on the recipient of service on reverse charge basis was under litigation in various judicial forms. The matter was settled by the decision of Hon'ble Bombay High Court in India....

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....rvice tax is a consumption/destination based tax and the services of commission agents were availed and used by the appellants located in India. The tax liability in such situation in terms of Section 66A has been upheld in numerous cases by the Tribunal and High Courts this has been elaborately discussed with the support of relevant case law in the impugned order. As such, we have no reason to in....

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....d. Admittedly, we find that the issue relating to service tax liability on the recipient of service was a subject matter of large number of litigations. The concept of reverse charge on import of service was new and was disputed. The legal position got clarified only with the decision of Hon'ble Bombay High Court in the case of Indian National Shipowners Association (supra). In such situation, we ....