2025 (12) TMI 1836

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ri Kishan, CA For the Respondent : Shri K. Raji Reddy, AR ORDER M/s Apoorva IT Solutions Pvt Ltd (hereinafter referred to as the appellant) are in appeal against the order of the Commissioner (Appeals) dt.19.06.2025, whereby, the Commissioner (Appeals) has partly confirmed the demand of Rs. 5,86,659/- and upheld the imposition of penalty under section 77 and 78 of the Finance Act, 1994 (i....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ue received on account of overriding commission from abroad was also reflected, which was treated as taxable value for providing intermediary service. The total tax for the period 2014-15 to 2017-18 (up to June, 2017) came to Rs. 68,92,952/-, out of which they had paid Rs.1,82,310/- during the period 2014-15. 3. Learned Advocate submits that they are not contesting the demand of service tax on ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the same is not leviable to service tax. 4. Learned AR, on the other hand, points out that while it is true that they had availed themselves of SVLDRS scheme for the period 2015-16 to 2017-18 (up to June, 2017), however, they had not availed themselves of the same for the period 2014-15, which is the subject matter of the present appeal. 5. Heard both sides and perused the records. 6. I f....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... entire case has been made based on certain disclosure made by the appellant themselves in the course of statement recorded by the investigating agency. It is also not in dispute that appellants themselves had voluntarily opted for the SVLDRS scheme involving the same issue. There is nothing on record that there was any deliberate attempt or intent on their part to evade payment of service tax. It....