Commissioner errs in applying reverse charge mechanism u/r 66 for payments between TTL Korea and TDCV Korea.

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....Levy of service tax - Business Auxiliary Service - applicability of reverse charge mechanism - There are no merits in the findings recorded by the Commissioner in para 19.3, highlighting the reasons for payment of service tax, after acknowledging that the services were provided by the TTL, Korea to TDCV, Korea. Commissioner also do not dispute that the entire payment for the services provided by TTL Korea was received by them directly from TDCV, Korea. Having acknowledged so Commissioner could not have come to the finding that these amounts were payment made by the appellant to TTL, Korea, for application of Rule 66 of the Finance Act, 1994. - AT....