2023 (3) TMI 695

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.... Bharath Kumar, Learned Chartered Accountant for the Appellant Smt. K. Komathi, Learned Additional Commissioner for the Respondent ORDER The appellant is a Private Limited Company engaged in providing knowledge process outsourcing. A perusal of the Show Cause Notice dated 08.04.2011 and the impugned Order-in-Original dated 03.04.2013 reveals that there was an investigation by the Survey, ....

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....the work of language translation from Chinese to other desired languages. It further transpires that the appellant had accounted the above transactions as "Translation Charges" in their books of accounts and made payments to the individuals. 2.2 By the above, it was alleged in the Show Cause Notice that the translation services received by the appellant from the various individuals were taxable....

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....nslation services constitute "support services of business or commerce" as defined under Section 65 (104c) of the Finance Act, 1994 and (2) whether the Revenue was justified in invoking the extended period of limitation? 5.1 We find that the period of dispute is from 2006-07 to 2010-11 and the tax demand was raised under reverse charge mechanism. Hence, when the tax is paid under reverse charge....

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....dicating Authority to the limited extent of working out the demand for the normal period. 6.1 We find from the impugned order that the Learned Commissioner has confirmed reduced penalty under Section 78 and penalty under Section 77 of the Finance Act, 1994. 6.2 In view of our discussions, we find that the Revenue has not made out any case of fraud, suppression, etc., and therefore, we set as....