2024 (2) TMI 304

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....ER ( TECHNICAL ) Shri B. Venugopal , Advocate for the Appellant Shri V. Srikanth Rao , AR for the Respondent ORDER [ Order per : ANIL CHOUDHARY ] Heard the parties. 2. The brief facts involved are as follows : (i) The Appellant is registered with Service tax department for providing different categories of taxable services and were paying appropriate Service tax. ....

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....d "Suspense account" or by any other name, in the books of accounts of a person liable to pay service tax, where the transaction of taxable service is with any associated enterprise." (iv) Correspondingly, an explanation was added to sub-rule (1) under Rule 6 of the Service Tax Rules, 1994 by Notification No. 19/2008-S.T., dated 10th May, 2008 as under: "Explanation - For the rem....

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....nting to Rs. 8,98,61,292/- on the amount of Rs. 72,70,33,100/- outstanding as on 10.05.2008 from M/s Swarnandhara IJMI Integrated Township Development Company Pvt. Ltd. (SITCO), which is an 'Associated Enterprises' as per Section 92A of the Income Tax Act, 1961 (since the Appellant holds 51% of share capital in SITCO). The said notice invoked the extended period of limitation under proviso to Sect....