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2022 Supreme(SC) 1277

D. Y. CHANDRACHUD, HIMA KOHLI
International Merchandising Company, LLC (Earlier Known as International Merchandising Corporation) – Appellant
Versus
Commissioner, Service Tax, New Delhi – Respondent


Advocates appeared:
For the Appellant(s) : Mr. S. Ganesh, Sr. Adv. Mr. Ashok Dhingra, Adv. Mr. Karan Bharihoke, AOR Mr. Siddhant Sharma, Adv. Ms. Sonia Gupta, Adv. Ms. Anushi Aggarwal, Adv.
For the Respondent(s): Mr. N. Venkataraman, ASG Mr. Arijit Prasad, Sr. Adv. Mr. Mukesh Kumar Maroria, AOR Mr. Shashank Bajpai, Adv. Mr. Madhav Singhal, Adv. Mr. V.C. Bharathi, Adv.

JUDGMENT :

Dhananjaya Y. Chandrachud, J

1. These appeals arise from a judgment dated 29 May 2020 of the Customs, Excise and Services Tax Appellate Tribunal1[“Tribunal”] in a batch of service tax appeals. The appeals before the Tribunal arose from an order dated 1 August 2013 of the Commissioner (Adjudication) which dealt with five show cause notices dated 20 October 2009, 20 April 2010, 20 April 2011, 23 March 2012 and 23 April 2013. The first of the five show cause notices invoked the extended period of limitation.

2. The appellant is engaged in providing diversified sports, entertainment and media services. It is registered with the jurisdictional service tax authorities under Chapter V of the Finance Act, 1994 for taxable event categories such as management consultant services, event management services, business auxiliary services, business exhibition services, and TV or radio programme production services. The appellant organizes events such as the Chennai Open Tennis Tournament and Lakme Fashion Week. It entered into various agreements, both domestic and international, with


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