2023 (6) TMI 954
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....cy's Services, the demand was for Rs.78,77,216/-. The Appellant has submitted before the Adjudicating Authority that the Works Contract Service undertaken by them were for various State Government approved projects and hence no Service Tax is payable. In respect of Manpower Services, they submitted that Show Cause Notice has been issued based on the Profit and Loss Account & Balance Sheet figures wherein total cost incurred on account of Labour Charges has been given. They submitted that they have engaged the Manpower/Labour directly and also through the contractors. They submitted the Chartered Accountant's Certificate to this effect. The Adjudicating Authority after going through the factual evidence and the statutory provisions, dropped ....
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....of the Certificate issued by the Chartered Accountant which has now been produced by him. Based on these facts, the Learned Chartered Accountant prays that the present Appeal may be allowed. 4. The Learned AR submits that the Adjudicating Authority had properly considered the Certificate issued by the Chartered Accountant and has dropped the demand to the extent of Rs.53.60 Lakh on the ground that the Appellant had engaged direct workers and hence no Service Tax is leviable on the same. Therefore, the AR submits that due consideration was given to the Chartered Accountant's Certificate by the Adjudicating Authority and now no further concession can be granted to the Appellant as is being pleaded by them in their Appeal. Accordingly, he sub....