P.G. Chacko, Judicial Member - After examining the records, we find that the appellants are air cargo agents of various airlines and are also a member of the IATA. In the impugned order, ld. Commissioner confirmed demand of service tax of Rs. 93,11,332 along with Education Cess against them for the period 1-4-2003 to 31-3-2006 and imposed on them penalties under sections 76 and 78 of the Finance Act, 1994 totalling to over Rs. 1.5 crores. The service tax demand is in the category of "Business Auxiliary Service" under section 65(19) of the said Act. Business Auxiliary Service (‘BAS’, for short) was introduced as a taxable service with effect from 1-7-2003. Therefore, the demand for the period prior to 1-7-2003 is, at once, unacceptable. For further purposes, we would consider the period from 1-7-2003 to 31-3-2006 as the period of dispute. During this period, the appellants received commission from various airlines, on whose behalf they booked cargo and collected freight charges from the consignees. It appears from the records that the entire demand of service tax is on the commission received by the appellants from the airlines. Ld. counsel for the appellants has fairly accepte