(Per : HONOURABLE MR.JUSTICE V. M. SAHAI)
1. We have heard Mr.D.K.Trivedi, learned counsel appearing for the appellant and Mr.Kalpesh N.Shashtri, learned counsel appearing for the respondent.
2. Notice is served on the respondent. Admit. We formulate the substantial questions of law as under:
1. Whether the learned Tribunal is justified in observing that the show cause notice is not barred by limitation in the facts and circumstances of the case ?
2. Whether the learned Tribunal is justified to observe that the activity undertaken by the appellant was covered under the purview of "manpower recruitment and supply agency" in terms of Section 65(68) of the Finance Act, 1994, in light of the facts and circumstances of the present case ?
3. Paper book be filed within three months ?
(V.M.SAHAI,J) (N.V.ANJARIA,J) ***vcdarji Top