2017 (12) TMI 554

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....tinizing the record of the appellant, the revenue entertained a view that they have availed services of foreign service providers and paid consideration for the same. The services are with reference to public offer of Foreign Currency Convertible Bonds (FCCB) and Global Depository Receipts (GDR). The services are rendered by M/s Elara Capital Lead Advisers Limited. The Revenue held a view that appellants are liable to pay service tax for availing such services under the category of banking and offered financial services (BOFS) on reverse charge basis. It was also held that the appellants are liable to pay service tax towards 'business auxiliary services' during the material time. Accordingly, proceedings were initiated which resulted in the....

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....nd and recover service tax under business auxiliary services. The original authority confirmed a part of the demand under 'advertising services' and 'internet telecommunication services.' This is clearly not sustainable. 3. The ld. AR supported the findings of the original authority. He submitted that as per the resolution passed by the shareholders of M/s Aksh Optifibre Limited, the whole of manufacturing facility of the company was transferred to the appellant. The assets and liabilities of such manufacturing unit is with the appellant. The original authority concluded that since the assets and liabilities are transferred to the appellant which is a 100 per cent subsidiary of M/s Aksh Optifibre Limited, it is apparent all the liabiliti....