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NOTE:
Yes. In the case of United Telecom [2010 (10) TMI 348 - CESTAT, BANGALORE], it was held that the Commissioner suggests that the activity of the appellant could be classified variously under clause (iii) of section 65(19) as service rendered on behalf of a client, as of a commission agent or, under clause (vii), as maintenance of accounts. The Commissioner does not give a finding as to the sub-clauses (i) to (vi) of section 65(19) to which maintenance of accounts related if the services fell under clause (vii). Moreover, there were no such proposals in the show-cause notice. We find that no tax liability can be confirmed against any person unless the same is specifically alleged in the show-cause notice.