2022 (10) TMI 287

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....ri Rajesh K Agarwal, Superintendent (AR) for the Revenue. ORDER The issue involved in the present case is that whether the appellant is liable pay service tax under the category of Commercial Training or Coaching Service for the computer training provided by the appellant to the students during the period 21.06.2006 to 30.11.2009. The case of the department is that the appellant is a Society for....

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....er. 3. On careful consideration of the submissions made by learned AR and perusal of the record, we find that he appellant have claimed that they are eligible for small scale exemption under the Notification No. 6/2005-ST as their total value is much below the threshold exemption limit of Rs. 10 Lakh per year. In this regard, we find that there is no dispute that the appellant are franchisee of S....

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....riod was invoked. We find that the issue is a neat question of law involving interpretation whether the same is falling under Commercial Training or Coaching Service and it is also observed that the appellant had a bonafide belief being a very small service provider having taxable value of Rs. 1,26,200/- that too in four years, they are eligible for small scale exemption under Notification No. 6/2....