2008 (8) TMI 144

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....500/- on M/s. K.R. Alloys Ltd. The short facts are that the appellants merely arranged for the acquisition of 75% of shares of M/s. Akshay Ispat & Ferro Alloys (P) Ltd., by one Shri S.K. Rataria. The Revenue has proceeded to consider such activity to fall within the ambit of 'Management Consultancy' service. This is contested by the appellant on the ground that the definition of 'Management Consultant' in terms of Section 65 (105) (r) of the Finance Act, 1944 (sic-1994) is "any service provided to a client, by a management consultant in connection with the management of any organisation in any manner". It is the submission of the appellant that merely helping to acquire 75% of equity of M/s. Akshay Ispat & Ferro Alloys (P) Ltd. and raising ....

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....ficatory Circular, this activity does not come within the ambit of Management Consultant which covers various functions and the multifarious activities required for efficient and effective functioning of an organization, any advisory services rendered in merger and acquisition transaction are also includible in the taxable services rendered by the management consultants. The learned Counsel submits that in terms of the Circular in para 11, such an activity would come under the ambit of 'Banking and Other Financial Services'. Therefore, the Circular also is not supportive to the Revenue. He points out that the Commissioner has merely relied on a portion of the Circular which is not correct. 3. The learned SDR strongly relies on the Circular....