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6. We have carefully considered the rival submissions of the learned counsel appearing for the parties and perused the material on record.
7. The nature of transaction as could be deciphered is that the anti virus computer software generated and supplied by the foreign based developers M/s McAfee Inc U.S.A and M/s. Symantec U.S.A., are marketed in India through M/s Ingram Micro India Ltd., Mumbai and M/s Redington (India) Ltd. The respondent is one of the channel partners effecting purchase of "anti virus software" from India based distributors and effecting sales of the same to the end customers. Up to this stage, there is no dispute regarding the payment of tax under the VAT Act for the sales of anti virus software effected by the respondent. But the controversy is with respect to the amount received by the respondent towards renewal of software licences raising service tax invoices.