TaxTMI 
TaxTMI 
2024 (1) TMI 1020
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....r hearing, Shri S. Sathyanarayanan, Ld. Advocate appearing for the appellant, would contend that the Revenue raised and confirmed the demand of Service Tax under the category of "manpower recruitment or supply agency service" only on assumptions and presumptions and they have also ignored the plea of the appellant, ignored the reply tendered by the service recipient namely, M/s. Continental Container Freight Station ('CCFS' for short); and that the alleged services having been rendered during 01.10.2006 to 31.03.2008, the Show Cause Notice dated 24.04.2012 has been issued by invoking the extended period of limitation without specifying any fraud, suppression of facts, etc., on the part of the appellant. It is thus his contention that the di....
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.... dated 03.04.2012 confirming that there was no agreement with the appellant and thereby also clarifying that the appellant had not charged Service Tax against the loading and unloading charges paid to him, wherein, at paragraph 6, to quote: "6. Mr. Maria Durairaj has not charged Service Tax against the loading & unloading charges paid to him. We were given to understand by him that being a cargo handling service to export cargo, the services are exempt from service tax. This was also raised by your Internal Audit party during the Financial Year 2008-09 and after discussions, the query was dropped and we also understand that no proceedings were initiated against Mr. Maria Durairaj." 5.3 From the above, it is to be understood that the carg....