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Corporate News *  Service tax penalty can’t survive when assessee acted on dept.’s own view of non-taxability: Delhi High Court. *  GST section 74 extended limitation questionable when form 26AS mismatch was already known: Karnataka High Court grants interim relief. *  CGST demand prima facie impermissible after state GST settlement under section 128A: Bombay High Court. *  Supreme Court asks GSTAT to sympathetically consider delay as taxpayers pursued remedy before wrong forum. *  Supreme Court stays Tripura High Court ruling protecting genuine buyers from ITC denial over supplier’s GST default. *  Diary entries alone can’t prove clandestine removal of goods: CESTAT quashes excise penalty on steel trader. *  Customs could investigate preferential tariff claims even before sec. 28DA: Delhi High Court. *  Customs dept. relied on fake AI generated case laws: supreme court quashes Rs. 425.28 crore penalty. *  No GST exemption in affiliation and annual registration charges for admission or conduct Of examinations: GSTAT. *  Mere invoices, cheque payments insufficient to establish genuine movement of goods: GSTAT restores Rs. 43.44 lakh ITC demand. *  Consolidated GST show cause notice covering multiple financial years is not without jurisdiction: Delhi High Court. *  Construction of independent houses on separate plots not taxable as ‘Residential Complex’ without common facilities: CESTAT. *  GST penalty exceeding statutory maximum unsustainable; Allahabad High Court quashes ? 50,000/- penalty after taxpayer filed return and paid late fee. *  GST order against standard chartered bank passed without hearing set aside by Bombay High Court. *  Retracted statements can’t be relied upon without cross-examination: CESTAT quashes gold confiscation. *  Burden to prove misclassification lies on customs department: CESTAT. *  CESTAT quashes Rs. 98 lakh excise demand on clearance of used refractory brick scrap. *  Service tax demand on irrigation works quashed: Karnataka High Court rules sale of goods component not taxable as service. *  GSTAT restores tax and penalty for transporting iron scrap without E-way bill citing intent to evade tax. *  Madras High Court stays GST recovery from directors without opportunity to show cause under section 89. *  Madras high court stays GST recovery notice against directors; finds prima facie case on applicability of section 79(1)(c). *  Procedural lapses can’t justify harsh punishment without serious customs breach: CESTAT quashes customs broker licence revocation. *  Service tax payable on land leasing and sports complex charges: CESTAT. *  Settled customs dispute can’t be reopened through Article 226 challenge to interest liability: Delhi High Court. *  Mere facilitation of customs clearance can’t establish knowledge of smuggling: Madras High Court. *  GST registration cancellation stayed: Allahabad High Court questions 99% ITC utilisation cap under rule 86B. *  Composition scheme lapses automatically on crossing Rs. 1.5 crore turnover: GSTAT. *  Gujarat High Court quashes GST cancellation orders after officer relied on non-existent AI-generated case laws. *  Importers liable for customs duty benefits availed through manipulated scrips: Delhi High Court. *  Procedural E-way bill lapse alone can’t justify penalty where genuine transaction and absence of tax evasion are established: GSTAT.
Subject News *  Documentary evidence dominates probe, further custody unwarranted: mumbai court grants bail in Rs. 22.44 crore customs duty evasion case. *  Business premises can’t remain sealed for non-participation in GST search: Allahabad High Court. *  GST pre-deposit must be refunded proportionately when taxpayer partly succeeds in appeal: Bombay High Court. *  Supreme Court grants 30 days to file GST appeal; keeps pre-deposit issue open due to deposit in parallel CGST proceedings. *  GST demand can’t exceed amount proposed in SCN: Allahabad High Court quashes Rs. 20.47 Crore order. *  Hundreds-of-crores GST demand and heavy 10% pre-deposit no ground to bypass statutory appeal: Punjab & Haryana High Court. *  Delhi High Court refuses to entertain challenge to gold confiscation due to statutory appeal remedy and unexplained delay. *  Procedural error in customs broker licence inquiry can be rectified through remand: Delhi High Court. *  GSTR-2A mismatch alone can’t justify ITC denial without invoice-wise verification; personal hearing mandatory: GSTAT. *  GST order passed without uploading personal hearing notices violates sec. 75(4): Allahabad High Court. *  TAX EVASION - Sec. 74 GST SCN quashed for not spelling out fraud, wilful misstatement or suppression: Allahabad High Court. *  STPI’s SOFTEX certification and NoC charges taxable as business support services: CESTAT. *  Suspicion can’t replace proof: CESTAT quashes penalty in alleged gold-smuggling operation. *   Limitation runs from communication of order: Madras High Court upholds rejection of delayed GST Appeals. *  Rajasthan High Court quashes GST demand over unsigned show cause notice. *  ITC recovery upheld where supplier failed to deposit GST: Rajasthan High Court. *  Customs commissioner’s empowered to make port trust liable for duty on pilfered goods: Supreme Court. *  Rectification proceedings can’t be used to challenge an uncontested GST assessment through a writ petition: Andhra Pradesh HC. *  GST proceedings against deceased proprietor unsustainable without notice to legal heir: GSTAT. *  Mere availment of ineligible self-assessed ITC doesn’t amount to suppression without evidence of fraud or wilful misstatement: GSTAT. *  Disposal of mining overburden by entity authorised by mining lease holder constitutes taxable service: CESTAT. *  Toll plaza data not mandatory for ITC refund: GSTAT. *  Disputed GST fraud allegations require investigation: Punjab and Haryana High Court makes interim bail absolute in alleged fraud and GST fraud case. *  Non-manufacturer contractor liable to deposit excess excise duty collected from buyer: CESTAT. *  GST order can’t reject taxpayer’s reply as “not satisfactory” without reasons: Madhya Pradesh High Court. *  Uncorroborated statements can’t establish alleged diversion of duty-free goods: CESTAT. *  Erection services were not liable to service tax prior to 10th september 2004: CESTAT. *  Sec. 74 GST notice must spell out statutory ingredients for invoking extended tax demand proceedings: Allahabad High Court. *  No jurisdictional bar under section 6(2)(b) in parallel CGST SGST proceedings: Delhi High Court refuses to bypass GST appeal remedy. *  Madras High Court remits GST demand for fresh adjudication after taxpayer claims it was unaware of SCN following business closure.  

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GST UPDATE No 253 ON CLARIFICATION ON LEVY OF GST ON LIQUIDATED DAMAGES

GST UPDATE No 253 ON CLARIFICATION ON LEVY OF GST ON LIQUIDATED DAMAGES
The levy of GST on liquidated damage, compensation, penalty, cancellation charges, late payment surcharge etc. arising out of breach of contract and the scope of entry at para 5(e) of Schedule II of the CGST Act, 2017 has been examined in the circular. There are many instances where a doubt arises as to levy of GST on charges such as compensation awarded against cancellation of license, bond amount recovered from an employee not serving the notice period, cancellation charges recovered for cancellation of railway tickets etc. The present update seeks to highlight the key takeaways of the said clarification issued vide Circular no. 178/10/2022-GST dated 03.08.2022 regarding the circumstances in which tax would be leviable on such charges.
 
It is stated that the service of agreeing to the obligation to refrain from an act or to tolerate an act or a situation, or to do an act is nothing but a contractual agreement. A contract to do something or to abstain from doing something cannot be said to have taken place unless there are two parties, one of which expressly or impliedly agrees to do or abstain from doing something and other agrees to pay consideration to the first party for doing or abstaining from such an act.
 
Agreement to do or refrain from an act should not be presumed to exist:- There has to be an express or implied agreement; oral or written, to do or abstain from doing something against payment of consideration for doing or abstaining from such act, for a taxable supply to exist. For instance, liquidated damages for breach of contract, forfeiture of salary for not serving notice period, penalty for cheque dishonour are not consideration for tolerating an act or situation as nobody enters into contract for leaving employment before the agreed notice period or for breach of contract. Hence, such payments are mere events in contract and will not constitute consideration or supply.
 
Similarly, examples of liquidated damages can be penalty for delayed construction of houses, forfeiture of earnest money by a seller for breach of contract etc. which are not liable to tax as such payments are merely flow of money and not a consideration for any supply.
 
On the contrary, pre-payment penalty on early repayment of loan , amount forfeited on cancellation of service by customer as contemplated by the contract as part of commercial terms agreed to by the parties constitute consideration for supply of a facility and so even if such payments are referred as fine or penalty, such payments are subject to GST.
 
As far as compensation ordered by the Supreme Court for cancellation of coal blocks allotted to successful bidders, it was clarified that no tax is required to be paid pursuant to the Apex Court order as no such promise or offer was made by the prior allottees to the government and that the allottees had no option but to accept the cancellation.
 
Likewise, cheque dishonour fine/penalty is not a consideration for any service as no supplier wants a cheque given to him to be dishonoured. Moreover, it entails extra administrative cost to him and disruption of his routine activities and cash flow.
 
As regards imposition of tax on penalty imposed for violation of laws is concerned, no GST is leviable as laws are not framed for tolerating their violation. Reference was also made to the Service Tax Education Guide issued in 2012 that fines and penalties for violation of the provisions of law are not considerations as no service is received in lieu of payment of such fines and penalties.
 
Forfeiture of salary or payment of bond amount in the event of the employee leaving the employment before the minimum agreed period:-Premature leaving of the employment results in disruption of work and an undesirable situation. The provisions for forfeiture of salary or recovery of bond amount in the event of the employee leaving the employment before the minimum agreed period are incorporated in the employment contract to discourage non-serious candidates from taking up employment. The said amounts are recovered by the employer not as a consideration for tolerating the act of such premature quitting of employment. Further, the employee does not get anything in return from the employer against payment of such amounts. Therefore, such amounts recovered by the employer are not taxable as consideration for the service of agreeing to tolerate an act or a situation.
 
Late payment surcharge or fee:-The facility of accepting late payments with interest or late payment fee, fine or penalty is a facility granted by supplier naturally bundled with the main supply. Almost all service providers across the world provide the facility of accepting late payments with late fine or penalty. Even if this service is described as a service of tolerating the act of late payment, it is an ancillary supply naturally bundled and supplied in conjunction with the principal supply, and therefore should be assessed as the principal supply.
 
Fixed Capacity charges for Power:-The fact that the minimum fixed charges remain the same whether electricity is consumed or not or it is scheduled/consumed below the contracted or available capacity or a minimum threshold, does not mean that minimum fixed charge or part of it is a charge for tolerating the act of not scheduling or consuming the minimum the contracted or available capacity or a minimum threshold. Both the components of the price, the minimum fixed charges/capacity charges and the variable/energy charges are charged for sale of electricity and are thus not taxable as electricity is exempt from GST.
 
Cancellation charges:-A supply contracted for such as booking of hotel accommodation, an entertainment event or a journey, may be cancelled by a customer or may not proceed as intended due to his failure to show up for availing the same at the designated place and time. The supplier may allow cancellation of supply by the customer within a certain specified time period on payment of cancellation fee as per commercial terms of the contract. It is stated that the facility of allowing cancellation against payment of cancellation charges is also a natural part of this bundle as it is invariably provided by all the suppliers as naturally bundled and in conjunction with the principal supply of transportation in the ordinary course of business. Hence, cancellation charges are to be assessed to tax as principal supply.
 
The above detailed circular seeks to discuss every possible nature of charges that can be treated in the entry “tolerate to do an act or refrain from doing an act” and its taxability in GST Law. It is submitted that we have already mentioned in our earlier GST update that every kind of liquidated damages or compensation is not to be treated as supply leviable to service tax unless there is express agreement to recover such compensation/damages in lieu of provision of the said service. The concept of substance over form in the agreements is the key deciding factor of whether the charges are liable to GST or not. Nonetheless, the above clarification will serve as a guiding tool to the assessees to determine their tax liability.
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