Mathew John, Technical Member - In this proceeding 10 COD applications, 6 stay applications and 42 appeals are being decided. Out of these 42 Appeals 15 are filed by assesses where the main issue is decided against the assessees and 27 by Department where the main issue was decided against the department. The facts and issues involved are common except that the facts and issues relating to Paul Merchants Ltd (hereinafter referred to as 'PML') are slightly different from that of others because PML is a main agent to Western Union Network Ltd. (hereinafter referred to as 'Western Union') and others are sub-agents to PML or to other main agents of Western Union similarly placed as PML.

Appeal No. ST-311/2009 filed by PML

2. The dispute relates to the period 01-07-2003 to 30-06-07.

3. PML entered into an agreement with Western Union Network Ltd, Ireland a company engaged in money transfer from persons located in one country to persons located in any country. PML was executing part of the activities, in territory assigned to PML in India, necessary for Western Union to carry out its business. The contract entered into between the two parties deals with remittances from persons abroad