Chartered Accountant
Bookmark and Share
click here to subscribe our newsletter
 
 
Corporate News *  GST registration cancellation without reasons amounts to ‘Economic Death’ of business: Supreme Court. *  No GST refund if appeal before GSTAT is filed late: Gujarat High Court. *  Mere upload of GST notice on portal not valid service, appeal limitation won’t start: Punjab & Haryana High Court. *  Taxpayer can’t be penalised for missing notices hidden under ‘Additional Notices/Orders’: Calcutta High Court allows fresh adjudication. *  State tax officer can’t issue GST SCN beyond CBIC-assigned jurisdiction: Bombay High Court stays recovery proceedings. *  Earlier 7.5% Pre-Deposit must count towards mandatory 10% for Appeal: Uttarakhand high court quashes CESTAT Order. *  Third Parties can’t challenge GST Advance Rulings merely due to financial impact: Karnataka HC *  GST SCN generated using AI tool quashed: Punjab & Haryana High Court *  Bank Attachment Quashed as Madras HC Quashes GST Order Issued Against Deceased Person *  ITC Blocking Order for Failure to Record ‘Reason to Believe’ U/R 86A Quashed: Allahabad High Court *  Govt Extends GSTAT Appeal Filing Deadline From 30 June to July 31, 2026 *  GST Demand on RWA Stayed: Allahabad High Court Questions Taxability of Electricity Distribution to Flat Owners *  CBIC Clarifies Jurisdiction After GST Registration Transfer: Earlier Proceedings Remain Valid, New Officer to Continue Action *  GST authorities’ certification not mandatory for reimbursement, but tax payment must be proven: Karnataka HC *  Contractor can’t seek gst reimbursement through writ when contract has arbitration clause: Karnataka HC *  Unsigned Order Is No Order in Law: AP HC Quashes GST Assessment Order for Want of Officer’s Signature *  Customs Can’t Levy Rs. 1.36 Crore Cost Recovery Charges Without Proof of Full-Day Officer Deployment: CESTAT  *  12% IGST Payable On Imported Dialysis Machine Parts: CESTAT *  Bombay High Court Admits Challenge to GST Limitation Extension Notifications; Grants Protection Against Coercive Recovery *  Criminal Case Can’t Run Parallel to GST Proceedings on Same Facts: Allahabad High Court *  Allahabad High Court Stays GST Detention Order; Directs Release of Vehicle and Goods on Deposit of Rs. 1.44 Lakh *  Service Tax Can’t Be Levied on Loss-Making Contracts: Gujarat High Court *  GSTN Mandates Ship-to GSTIN in e-Invoice and e-Way Bill APIs; Introduces Voluntary e-Way Bill Closure Facility from August 1, 2026 *  GST Appeal Can’t Be Rejected as Time-Barred When Taxpayer Was Pursuing Rectification Remedy: Telangana High Court *  Absence of E-Way Bill and Transport Documents Justifies Customs Seizure U/s 110: Gauhati HC *  Madras High Court Upholds GST Late Fee and Penalty for Non-Filing of Annual Return, Dismisses Challenge  *  GST Records, Purchase Documents Sufficient to Discharge Burden Under Customs Act: CESTAT Orders Release of 3.65 Kg Gold  *  No Sugar Cess Payable on Sugar Exported Out of India: CESTAT *  Road Construction Services Exempt and SCN Time-Barred: CESTAT Quashes Service Tax Demand Based Solely on Form 26AS  *  ITC Freeze Upheld After GST Dept Find Suppliers Were Allegedly Fake Bill-Trading Entities: Madras HC 
Subject News *  Input service benefits can’t be denied: CESTAT allows export refund despite MMTC acting as Canalising agency. *  No service tax demand without proof of service of SCN: CESTAT. *  Service tax demand quashed as dept. fails to prove service of SCN: CESTAT *  GST : Mere allegation of inadequate consideration of reply not enough to invoke writ jurisdiction: Delhi High Court *  Onerous conditions imposed for provisional release of seized imported goods shouldn’t amount to virtual denial of relief: CESTAT. *  GST SCN without alleging fraud cannot invoke sec. 74: Karnataka High Court quashes adjudication order. *  Extended Limitation Can’t Be Invoked Merely on Form 26AS Data: CESTAT *  Revenue-Sharing with Restaurants Not Taxable as Business Support Service: CESTAT *  R. 6(3) Option Can’t Be Forced on Taxpayer; CESTAT Quashes Rs. 12.36 Crore CENVAT Credit Demand *  Excise Duty | Power Consumption Alone Can’t Prove Clandestine Manufacture: Karnataka High Court *  Madras High Court Examines DGGI’s Authority to Issue GST Penalty Orders Under Section 122, Adds DGGI as Party *  Proceedings under omitted r. 96(10) can’t survive without saving clause: andhra pradesh high court quashes gst refund recovery *  Excise duty power consumption alone can’t prove clandestine manufacture: karnataka high court *  Madras high court rules GST show cause notices must disclose grounds for invoking extended limitation *  Court Can’t Direct Extension GST Return Deadlines or Waive Interest and Penalties: Karnataka High Court *  GST Notifications Can’t Go Beyond GST Council Recommendations: Madras High Court Quashes SCN on Branded Pulses *  Appeal Can’t Be Dismissed for Delay When Dept’s Own Order Mis-states Limitation Period: CESTAT *  No Evidence of KYC or Due Diligence Breach By Customs Broker: CESTAT Quashes Licence Revocation in Export Overvaluation Case *  Glucometers Are Chemical Analysis Instruments Classifiable Under Tariff Heading 9027: CESTAT *  Validity of Post-GST Service Tax Proceedings Upheld: Gujarat High Court Dismisses Challenge to S. 73 SCN *  Rectified GST Refund Applications Can’t Be Rejected as Time-Barred If Original Refund Claim Was Filed Within Limitation: Gujarat HC *  Service Tax Refund Can’t Be Denied as Time-Barred When Levy Itself Is Unconstitutional: Gujarat High Court *  Same Officer Can’t Act As Auditor & Adjudicator: Karnataka High Court *  Karnataka High Court Condones 324-Day Delay, Revives Customs Appeal in Jewellery Pilferage Case  *  Madras High Court Quashes GST Assessment Order Passed Ex Parte Despite Prior ITC Reversal; Lifts Bank Attachment *  Tobacco Process Doesn’t Amount to Manufacturing: Madras High Court Quashes Rs. 1.32 Crore Compensation Cess Demand  *  Recovery Notice Unsustainable After Voluntary Reversal of Unutilised Credit: CESTAT  *  GST | ‘System Generated’ SCN Without Officer Details Invalid: Allahabad HC  *  Electronic Records Without Statutory Certification Requirements Can’t Justify Undervaluation Allegations: CESTAT *  Madras High Court Stays GST Order, Finds Prima Facie Merit in Plea Against S. 74 Proceedings Based on S. 73 Intimation  

Comments

Print   |    |  Comment

PJ/Case Law/2014-15/2388

New ground cannot be taken at the appellate stage.

Case:-SANJAY ELECTRICAL Vs COMMISSIONER OF SERVICE TAX, NOIDA

Citation:-2014-TIOL-340-CESTAT-DEL

Brief facts:-Adjudication order dated 29.08.2012 confirms a composite service tax demand of Rs.50,27,977/- besides interest and penalty as specified therein on the ground that petitioner provided four categories of taxable services including (i) commercial or industrial construction service, the tax liability for which is assessed as Rs.68,500/- ; (ii) construction of residential complex service, which is assessed to Rs.3,63,742/-. At the present stage of the proceedings, ld. Counsel for the petitioner/appellant, Shri A.K. Batra does not contest the classification of these services nor the quantum of tax liability assessed as relatable to these services. It is however submitted by the ld. Counsel that the petitioner has remitted Rs.3,97,273/- plus the applicable interest thereon in respect of these services. The total assessed tax liability on these two services is Rs.4,34,272/-. The balance tax liability on these two services viz. commercial or industrial construction service and construction of residential complex service is thus Rs.35,000/- (approx.). In respect of erection, commissioning and installation services, the petitioner urged several contentions including that all the petitioner's activities alleged and classified by Revenue to constitute erection, commissioning and installation service were provided under composite contracts involving rendition of service and deemed sale of goods as well and therefore ought to be classified as works contract service and are classifiable under Section 65(105)(zzzzh) of the Finance Act, 1994. The tax liability assessed on erection, commissioning and installation, is Rs.26,01,012/-. Prima facie, since the period in dispute is 1.4.2010 to 31.03.2011, subsequent to introduction of works contract service, which is an independent taxable service and undisputedly the services provided by the petitioner are under composite contracts involving rendition of service and deemed transfer of the goods during the course of executing the works, these should prima facie be classified as work contract. The petitioner's claim for execution of the value of the goods incorporated, claimed to be to the extent of 90% of the gross consideration received was not accepted on the ground that no proof was furnished regarding the value of goods or deemed to have been sold during the course of rendering the service. The Commissioner granted the benefit of abatement of 67% only under Notification No.1/2006-ST.

Appellant contention:-It is submitted that the petitioner has made out a strong prima facie case in respect of the levy of Rs.7,87,000/- out of 19,94,813/- assessed as liable for management, maintenance or repair service. The balance of Rs.12,07,178/- is assessed for having provided Management, Maintenance and Repair service covered by works contracts involving operation and repair of pump houses and diesel generating sets at different locations for the Ganga Jal Distribution Scheme of Noida. The agreement between the petitioner and the Noida Authority requires the petitioner to depute qualified Pump Operators to run the Diesel Sets; Electricians to provide round the clock operations and generally to keep the DG sets and pump houses in a state of constant operation. Ld. Counsel for the petitioner contends that these activities do not fall within Management, Maintenance or Repair service, since the essential nature of the activity is operation of the DG sets and pump houses and that Management, Maintenance and Repair is merely incidental to that primary purpose. Further the petitioner has also contended that the adjudication order is unsustainable for want of jurisdiction by the Commissioner, Noida, since the petitioner is resident at Delhi.

Reasoning of judgment:-The tribunal is not inclined to consider this contention at this stage of the proceedings since the material on record does not reflect this objection having been raised before the adjudicating authority. Whether exercise of the jurisdiction by Commissioner, Noida is valid requires a deeper analysis. Since the service falls within the ambit of works contract service, an independent taxable service, introduced w.e.f. 1.6.2007 and is required to be classified only as works contract service, in view of the classification discipline mandated by Section 65 (A) of the Act, the amount of Rs.26,01,012/- being the tax liability assessed on Erection, Commissioning and Installation service is unsustainable. Insofar as Management, maintenance or repair service is concerned, according to the ld. Counsel, the tax liability on this is assessed as Rs.19,94,813/-. Of this amount Rs.7,87,000/- is on account of a contract involving shifting and strengthening of electric lines and street lights in different specified locations. On prima facie analysis of the provisions of this contract, this service falls more appropriately under erection, commissioning and installation but not within the ambit of management, maintenance or repair. The definition of Management, Maintenance and Repair service under Section 65(64) of the Act is any service provided under a contract or agreement by the manufacturer or any person authorized by him, in relation to, management of properties, whether immovable or not; maintenance or repair of properties, whether immovable or not; or maintenance or repair including reconditioning or restoration, or servicing of any goods, excluding a motor vehicle. The agreement between the petitioner and the Noida Authority requires the petitioner to take over the operation of DG sets and the pump houses and cater to the management, maintenance and repair of these equipment and infrastructure as well. The management of these movable or immovable properties is the essence of the agreement and the maintenance or repair is integral to the, overall assumption of the management function. Though ld. Counsel for the petitioner has relied on judgements of this Tribunal including CMS (I) Operations and Maintenance Co. Pvt. Ltd. reported in 2007 (7) STR 369 (Tribunal-Chennai) = (2007-TIOL-892- CESTAT-MAD) and Wartsila India Ltd. reported in 2011 (22) STR 338 (Tribunal-Mumbai), we find that on a perusal of these decisions, that there is no analysis on or reference to provisions of Section 65(64) of the Finance Act, which defines the taxable service of Management, Maintenance and Repair.

We therefore grant waiver of pre-deposit and stay all further proceedings pursuant to the adjudication order dated 29.08.2012 passed by the commissioner, Customs & Service Tax, Noida on condition that the petitioner remits Rs.12,42,000/- (comprising Rs.1,27,000/- on management, maintenance or repair service and Rs.35,000/- towards the balance liability on commercial or industrial and residential complex services) plus the proportionate interest thereon, within six weeks and report compliance by 11.3.2014. In default, the stay shall stand dissolved and appeal shall stand dismissed for failure of pre-deposit. The ld. counsel for the petitioner is present in the court and undertakes to intimate to the petitioner its obligations under this order.

The stay application is disposed of as above.
 
Decision:-Part pre-deposit ordered.
 
Comment:-The substance of this case is that at the appellate stage, it is not possible to take entirely new ground that has not been taken at the adjudication stage. As the ground of jurisdiction was taken for the first time before the Tribunal, the same was not accepted and pre-deposit was ordered.
 
Prepared by: Shubham Sancheti

Department News


Query

 
PRADEEP JAIN, F.C.A.

Head Office : -

Address :
"SUGYAN", H - 29, SHASTRI NAGAR, JODHPUR (RAJ.) - 342003

Phone No. :
0291 - 2439496, 0291 - 3258496

Mobile No. :
09314722236

Fax No. :0291 - 2439496


Branch Office : -

Address:
1008, 10th FLOOR, SUKH SAGAR COMPLEX,
NEAR FORTUNE LANDMARK HOTEL, USMANPURA,
ASHRAM ROAD, AHMEDABAD-380013

Phone No. :
079-32999496, 27560043

Mobile No. :
093777659496, 09377649496

E-mail :pradeep@capradeepjain.com