![]() – The services being rendered by VSL International to The assessee will continue to be rendered by VSL International – the services rendered by VSL Hong Kong shall henceforth be rendered by VSL International on the same terms and conditions “it has been considered expedient and convenient that Subsequently, three Show Cause Notices were issued to the assessee, the details of which are as under:-Ħ.1 The Show Cause Notice dated issued by the Commissioner captures, at paragraph 2.1.1, the salient features of the above MOU with M/s.dated by wrongly classifying the services imported from its group companies and (ii) non-inclusion of TDS in the taxable value of services received from outside India, were noticed, which prompted the issuance of Show Cause Notice dated. It appears that there was an audit of accounts of the appellant by the Internal Audit Group of the Service Tax Commissionerate wherein: (i) wrong availment of exemption under Notification No.VSLI, which appears to be in furtherance to the earlier agreements between the two parties. A Memorandum of Understanding (MOU) dated was drawn between the appellant and M/s.VSL, Hong Kong for providing assistance in managerial, financial, sales, marketing, controls and audit, taxes, personnel and training and technical services. Thus, an agreement was signed between the appellant and M/s. VSLI and all other subsidiary and affiliate companies with whom separate service agreements could be entered into. ![]() VSLI’ for short) dated whereby the holding company was to provide the appellant with requisite technical assistance in the fields of consultancy, advisory, operation and other services, as per the terms contained in the above agreement it was also clear that the above services were to be provided by the VSL group as such, including M/s. ![]() VSL International Ltd., Switzerland (‘M/s. The assessee had entered into an ‘Offshore Services Agreement’ with their holding company namely, M/s.
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