(1.) THE appellants are required to pre -deposit service tax amount of Rs. 1,61,328/ - and penalty of Rs. 1,71,328/ -. They were not including loading and unloading charges in bills for C & F services. Hence the demand was raised invoking larger period. The learned Counsel submits that the appellant is willing to deposit an amount of Rs. 1,14,000/ -. He contest the matter on merit as the activity of loading and unloading is not a part of service rendered as C & F agents.
(2.) THE learned DR submits that the loading and unloading is a part of service as it is the main ingredient of the activity.
(3.) THE learned Counsel also contests the case on time bar.