UNITECH LIMITED Vs. CST

JUDGEMENT

(1.) THE main point of dispute in this case is as to whether during the period from 01/8/02 to 16/6/05, the Appellants received Architect's services from M/s Callison Architecture Inc., U.S.A. (hereinafter referred to as M/s Callison), who do not have any office or business establishment in India and whether the Appellants, as recipient of a taxable service from an offshore service provider are liable, in term of Rule 2(1)(d)(iv) of the Serviced Tax Rules, 1994, to pay service tax amounting to Rs. 1,83,10,592/ - on an amount of Rs. 22,61,54,796/ - paid by them to M/s Callison.

(2.) The Commissioner by the impugned order has -

(3.) WE have given careful consideration to the submissions from both the sides.