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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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Publish Date: 30 Jun, 2012
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The Bermuda Triangle Mystry Created by Negative List

 

THE BERMUDA TRIANGLE MYSTRY CREATED BY NEGATIVE LIST

 

An article by:-
 
CA. PRADEEP JAIN
CA. PREETI PARIHAR

 
Introduction:-
 
After six years of uncertainties, finally section 66A of the Finance Act, 1994 has few more days to survive. 1.7.2012 is the day when this section will cease to exist. On this date, Export of Services Rules, 2005 and Taxation of services (Provided from outside India and received in India) Rules, 2006 will also extinguish. In place of these, a new charging section 66B will come into force and instead of import-export rules, a new set of rules namely, Place of provision of services rules, 2012 will be implemented. In this article, an effort has been made to bring out its impact on the import of intermediary services from abroad.
 
New charging section:-
 
Under negative list, new charging section has been proposed in the Finance Act, 1994 which is section 66B. This section reads as follows:-
 
“66B. There shall be levied a tax (hereinafter referred to as the service tax) at the rate of twelve per cent. on the value of all services, other than those services specified in the negative list, provided or agreed to beprovided in the taxable territory by one person to another and collected in such manner as may be prescribed.”
 
Thus, according to new charging section, all the services provided in the “TAXABLE TERRITORY” will be taxable unless specified in the negative list or under mega exemption notification. The word “taxable territory” means the whole of India except Jammu and Kashmir. Thus, if the services are provided at a place outside taxable territory, it will be exempted.
 
Where the service is provided?
 
The new charging section says that the services provided outside taxable territory will not be chargeable to tax in India unless otherwise provided. Now, where the services are actually provided is the key determinant of the taxability of a service. There may be cases where the provision of service may be deemed at the place of service provider as well as at the place of service recipient. In order to meet these ambiguities and to determine the place of providing the service, the Place of Provision of Services Rules, 2012 have been proposed.
 
Intermediary services and Place of provision of services Rules, 2012:-
 
Rule 9 of Place of provision of service rules provides that the place of providing of service will be deemed as location of service provider in case of services specified under this rule. This rule reads as follows:-
 
“Place of provision of specified services.- The place of provision of following services shall be the location of the service provider:-
 
a)    Services provided by a banking company, or a financial institution, or a nonbanking financial company, to account holders;
 
b)    Telecommunication services provided to subscribers;
 
c)     Online information and database access or retrieval services;
 
d)    Intermediary services;
 
e)     Service consisting of hiring of means of transport, upto a period of one month.
 
The rule 9 includes the “intermediary services” in the list of specified services on which this rule applies. The intermediary services being explained in guidance note 3 issued by TRU as follows:-
 
An “intermediary” is a person who arranges or facilitates a supply of goods, or a provision of service, or both, between two persons, without material alteration or further processing. Thus, an intermediary is involved with two supplies at any one time:
 
i) the supply between the principal and the third party; and
ii) the supply of his own service (agency service) to his principal, for which a fee or commission is usually charged.
 
For the purpose of this rule, an intermediary in respect of goods (commission agent i.e a buying or selling agent) is excluded by definition. In order to determine whether a person is acting as an intermediary or not, the following factors need to be considered:-
 
Nature and value: An intermediary cannot alter the nature or value of the service, the supply of which he facilitates on behalf of his principal, although the principal may authorize the intermediary to negotiate a different price. Also, the principal must know the exact value at which the service is supplied (or obtained) on his behalf, and any discounts that the intermediary obtains must be passed back to the principal.
 
Separation of value: The value of an intermediary’s service is invariably identifiable from the main supply of service that he is arranging. It can be based on an agreed percentage of the sale or purchase price. Generally, the amount charged by an agent from his principal is referred to as “commission”.
 
Identity and title: The service provided by the intermediary on behalf of the principal is clearly identifiable.
 
In accordance with the above guiding principles, services provided by the following persons will qualify as ‘intermediary services’:-
 
i) Travel Agent (any mode of travel)
ii) Tour Operator
iii) Stockbroker
iv) Commission agent [an agent for buying or selling of goods is excluded]
v) Recovery Agent
 
Even in other cases, wherever a provider of any service acts as an agent for another person, as identified by the guiding principles outlined above, this rule will apply.          
 
Thus, the rule 9 specifies in case of specified services, place of provision of service will be location of service provider. The list of specified service includes intermediary services. The intermediary services have been specified as tour operator, stock broker, travel agent, commission agent (except buying & selling agent) and recovery agent. Thus, on these services if imported from outside India; rule 9 of Place of provision of services rules will be applicable and accordingly, the place of providing the service will be deemed to be location of service provider, i.e. non taxable territory. Accordingly, no service tax would be levied under section 66B as the service is deemed to be provided in non taxable territory.
 
Impact of rule 9 of POP Rules, 2012:-
 
“Intermediary services” has been specified as one of the services on which rule 9 is applicable. Intermediary services include the mediator/agent who act on behalf of any person commonly known as principal. Thus, where a person located in abroad acts on behalf of the principal located in India and in turn receives commission from Indian principal, though it will be deemed as import of service from abroad, still no service tax would be payable in view of rule 9 of POP Rules, 2012. Further, travel agents are also included in this rule. The availment of services of foreign travel agent is very common practice in big hotels. In terms of rule 9, the place of the service in such cases would be Location of service provider, i.e. the location of foreign travel agent, which is outside the taxable territory of India. Therefore, the transaction will be exempt from the service tax. This provision resembles to the notification no. 13/2008-ST dated 1.3.2008 where the commission received from foreign travel agent was exempt subject to certain conditions. Thus, the benefit of this notification is being carried onto negative list without any conditions.
 
Principal-agent v/s principal to principal relationship:-
 
If the agent-principal relationship is satisfied between the service provider located in abroad and principal located in India, these will be treated as intermediary services (except in case of buying-selling agent). However, if both the parties are acting on principal to principal basis, the services provided from abroad will not be considered as intermediary services. As such, the rule 9 will not be applicable, rather, the general rule 3 of these rules will be applicable which reads as follows:-
 
3. Place of provision generally. - The place of provision of a service shall be the location of the service receiver”
 
Therefore, if the relationship between the foreign service provider and the Indian recipient is on principal to principal basis; the rule 3 will be applicable and thus in that case, the place of providing the service shall be deemed as the place of service receiver, i.e. India. Therefore, in this case, since the services are deemed to be provided in taxable territory, service tax would be payable by the recipient of services located in India.
 
Rule 9 v/s rule 3 of POP services Rules, 2012 – a tax planning tool:-
 
In the cases where the service provider is located abroad and service recipient is located in India and where the nature of service is arranging or facilitating the supply of goods, or a provision of service, or both, between two persons; if one is able to prove the agent principal relationship, service tax may be avoided. We can say that eventhough both the service provider and recipient have been acting on principal to principal basis and consideration received may be in nature of profit; but in future for tax planning, the agreement will more likely be draft in a manner to reflect that there is agent-principal relationship and the consideration so received is “commission”. Thus, one door is being opened to enjoy the tax exemption in like cases under the above rules.
 
If everything is fine as above, then where’s the problem?
 
All the above discussion indicates that many of the imported services that are taxable under the current provisions will become exempt under negative list. This doesn’t seem to be the intention of the government. If it was the intention of law makers, then in the notification no. 15/2012-ST dated 17.3.2012, clause no. 10 would not have been inserted. This notification prescribes the person liable to pay the service tax in specified cases. Clause no. 10 reads as follows:-
 
“in respect of  any taxable services  provided or agreed to be provided  by any person who is located in a non-taxable territory and received by any person located in the taxable territory” – the 100% service tax will be payable by the service recipient.
 
Thus, under reverse charge method if the service is “PROVIDED BY A PERSON LOCATED IN NON TAXABLE TERRITORY” and is “RECEIVED BY A PERSON LOCATED IN TAXABLE TERRITORY”, the service tax will be payable by the service recipient. In other words, in each and every case, where the location of service provider is non taxable territory and location of service recipient is taxable territory, the service tax will be payable by the service recipient. But how this notification will work? If we read charging section 68, it indicates that the in order to be chargeable to service tax, the service should be provided in taxable territory. If not provided in taxable territory, no service tax would be levied. Read with this section, the Place of provision of service rules, 2012 have been issued which determines what will be the place for providing the service? If the place for providing the service is taxable territory as per these rules, pay the service tax and if the place of providing the service is non taxable territory, no service tax is payable. On the other hand, the above notification no. 15/2012-ST even does not speak where the service should be provided? It simply says that the service should be provided by a person located in a non taxable territory and it should be received by the person located in taxable territory and if these two conditions are satisfied, the recipient of the service will be liable to pay the service tax.
 
Now if we read charging section 68 with Place of provision of services rules, 2012; there is absolutely no doubt. However, if we read section 68 with notification no. 15/2012-ST, both contradicts as section 68 gives emphasis on the “place of providing the service” whereas notification emphasizes on “location of service provider & recipient”. Going further, if we read all the three – section, notification and rules all together, everything is mess up and no clear derivation may be made. It needs the timely clarification else the situation will be even worse than earlier section 66A.
 
While winding up:-
 
Government has made serious efforts to replace existing section 66A, Export of Services Rules, 2005 and Taxation of services (Provided from outside India and received in India) Rules, 2006 by the section 66B, Place of Provision of services Rules, 2012 and Notification no. 15/2012-ST dated 17.3.2012. But whether these efforts will pay the government or the unfortunate assessees will pay for this “Bermuda Triangle” created by the negative list…
Department News


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PRADEEP JAIN, F.C.A.

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