2019 (11) TMI 1511

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....II that is now impugned before us, in notice dated 24th April 2014 comprised enhancement of taxable value to the extent of Rs. 4,03,59,754 and recovery of Rs. 12,51,61,661 as provider of 'support services of business or commerce', 'business auxiliary service' and 'technical testing and analysis agency service' and as person liable to pay tax for availing 'goods transport agency service' between April 2008 and March 2012 and statement of demand of Rs. 5,42,37,994 for the period from April 2012 to June 2012. The impugned order has, however, restricted the demand to Rs. 1,18,50,780 leviable on providing of 'technical testing and analysis agency service' and Rs. 2,96,387 on providing of 'renting of immovable property service', 'commercial coach....

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....garding a clinical trial provided that all such contractual transfers or obligations are defined in writing' and the exemption notification supra as applying to 'taxable service provided or to be provided by a Clinical Research Organisation approved to conduct clinical trials by the Drugs Controller General of India, in relation to testing and analysis of newly developed drugs, including vaccines and herbal remedies, on human participants so as to ascertain the safety and efficacy of such drugs on human participants' it would appear that the denial of exemption is founded on this. 5. The adjudicating authority has inferred that the approval of the institution by the Drugs Controller General of India is not substitutable with specific a....