ST : If service provider has imparted training or coaching for a consideration,

ST : If service provider has imparted training or coaching for a consideration, then, such consideration per se determines commercial character of activity and it would be regarded as 'commercial training or coaching'; absence of profit motive or constitution of service provider are irrelevant.

ST : Where no final judgment in support of assessee's views exists during period of dispute, there cannot be any "bona fide belief based on decisions" so as to avoid invocation of extended period of limitation; accordingly, extended period of 5 years is invocable and it can be reckoned from date of acquisition of knowledge by department.



[2013] 37 taxmann.com 42 (Bangalore - CESTAT)

CESTAT, BANGALORE BENCH

I.C. Financial Analysts of India

v.