Commissioner (Appeals) wrongly taxed payments to Honda Japan as consulting services under reverse charge mechanism. No evidence of service.

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....Levy of Service tax - Reverse Charge Mechanism - consulting engineer service - amount paid to Honda Japan under the Technical Agreement - the amount was paid to compensate Honda Japan for the research and allied work it had performed at its end and not towards supply of any technical information to the appellant. In the absence of any evidence to the contrary, the Commissioner (Appeals) could not have concluded that the aforesaid amount was paid by the appellant to Honda Japan for rendering any taxable service. - AT....