Chartered Accountant
Bookmark and Share
click here to subscribe our newsletter
 
 
Corporate News *  The GSTN has issued an Advisory dated 21.04.2026 about the introduction of an Offline Tool for the Invoice Management System (IMS)  *  CBIC extends due dates for filing of FORM GSTR 3B  for the month of April 2026 *  Interest cannot be imposed in adjudication order, if not demanded/quantified in show cause notice : Allahabad HC *  Wheelchairs with toileting facility eligible for exemption: CESTAT affirms customs duty exemption to importer *  Industries urge GST council to allow inverted duty refunds on input services *  Tamil Nadu GST dept introduced virtual hearing facility for GST appeals under under section 107 of the TNGST act: detailed guidelines  *  CIC urges authorities to implement GST evasion complaint tracking system *  Even if the assessee opts "NO" for personal hearing in form DRC-06 ,The mandatory requirement under section 75(4) to grant opportunity of hearing cannot be waived:Gujarat High Court  *  Glufosinate imports curbs imposed by govt *  Government extends Re-import period for exported cut & polished diamonds *  CIC flags lack of tracking system for tax evasion complaints,urges GST authorities to improve transparency *  No Custodial Interrogation needed in GST fraud case based on documentary evidence already in Department's Possession : Chattisgarh HC *  Orders under section cannot be sustained if passed without considering the taxpayer's objections and without granting a personal hearing:Gujarat High Court *  Mere cancellation of supplier's registration cannot,by itself,justify denial of ITC or cancellation of the recipient's registration:Bombay High Court *  High Court sets aside GST notice citing factual errors and natural justice violations *  Provisional Bank Attachment under Section. 110 of Customs Act Unsustainable Beyond Statutory period without Extension order: Bombay HC orders to defreeze accounts *  Post Clearance MRP Alteration by Distributor Does not attract Differential Customs Duty: CESTAT *  DGFT Expands scope of 'Screws' classification under RoDTEP Scheme  *  E-way bills surze to all time high of 140.6 million in March *  GST Exemption Allowed on Pure Labour Services for Standalone Houses: AAR  *  GST Payable Only on Margin in Second-Hand Car Sales, Subject to Strict Conditions and No ITC Claim: AAR *  DGFT rolls out procedure for allocation of calcined coke *  GST portal update : Pre-deposit amount now editable in Appeals *  J&K HC declared TMT scrap a 'Specified Good' eligibile for GST refunds under Support Scheme  *  Pigmy agents are employees of banks; no GST can be levied on commission  paid to them : Karnataka HC *  DGFT Revises HS Code Description for Screws Under RoDTEP *  GST Registration Cancellation Invalid Without Proper Service of Notice: Allahabad High Court. *  Bengaluru CGST | GST Backlog Appeals Deadline Fixed at June 30, 2026 *  No Time Bar on Refund of Service Tax for Services Not Rendered: CESTAT  Remands Indiabulls Case for Unjust Enrichment Check. *  Supreme Court Holds Renewable Energy Incentive Must Benefit Generators, Not Be Adjusted in Tariff
Subject News *   Delhi HC Quashes Order, Says Reminder Cannot Validate Improperly Served GST SCN *  KARNATAKA HIGH COURT REMANDS GST SHORTFALL MATTER DUE TO ABSENCE OF PERSONAL HEARING   *  CESTAT cancels confiscation and penalties on imported computer cabinet cases: Custom duty restricted to 111 surplus units *  Deposit of tax during search or investigation cannot be treated as 'Voluntary Payment' : Bombay High Court *  Section 76 of the CGST cannot be invoked where the tax has already been duly deposited, even if through another registration of the same entity: Madras High Court *  Sec 74 allows use of material regardless of source; illegality or flaws in section 67 search do not vitiate valid adjudication: HC *  Inter-State transfer of ITC on Amalgamation permissible as given under section 18(3) read with rule 41 of the CGST rules, 2017: Gujarat High Court *  HC: No GST on commisson paid to Pigmy Agents *  IGST refund denial on illegible bill of lading invalid absent chance to furnish docs; merit reconsideration in appeals directed: HC *  ITC is not admissible on GST paid on leasehold rights of land used fpr setting up an air seperation plant: AAAR,Tamil Nadu *  GST: No penalty under Section 74 after voluntary ITC reversal due to non-existent supplier : High Court *  TN AAAR denies GST ITC on Land Lease under Sec. 17(5)(d) for setting up plant and machinery *  GST proceedings quashed as notices sent to old address, despite updated address in registration *  Importer Can’t Be Penalised for Alleged IGCR Procedural Lapses Without Evidence of Departmental Error: CESTAT *  Structured Healthcare Training Not ‘Charitable Activity’, 18% GST Payable: AAR  *  CESTAT As The Appellate Authority For Central Sales Tax Disputes: A Paradigm Shift Under Finance Act, 2023 *   Rs. 25K Cost Imposed On SGST Joint Commissioner for Attaching Bank  Accounts Without Forming Mandatory “Opinion”: Bombay HC *   Ex-Parte GST Order Without Hearing Violates Natural Justice: Karnataka  High Court Quashes Adjudication and Bank Attachment.  *   Retrospective GST Cancellation Can’t Invalidate Genuine Transactions:  Jaipur Commissioner (Appeals) Quashes Rs. 95,670 ITC Demand. *   GST Pre-Deposit Non-Compliance: Allahabad High Court Allows Appeal  Subject to Rs. 30 Lakh Balance Deposit, Recognises Offline Filing. *  Documentary Nature of Evidence: Allahabad High Court Grants Bail in Rs. 32.66 Crore Fake ITC Fraud Case *  Supreme Court Flags Systemic Bias in Army’s Permanent Commission Process for Women Officers *  Re-Determination of Land Compensation Can Be Based on Appellate Court Awards, Clarifies Scope of S. 28-A: Supreme Court. *  Supreme Court Imposes Rs. 5 Lakh Costs On Rent Authority Officer For Acting Beyond Jurisdiction. *  DGGI Meerut | Court Denies Bail to Accused in Claiming Fake ITC And Export Refunds *  Denial of GST Rate Revision Benefit to Contractor Violates Article 14: Rajasthan HC *  GST Registration Cancellation for Non-Filing of Returns: Gauhati High Court Directs Restoration on Compliance. *   Supreme Court Quashes FEMA Adjudication Orders, Revives Proceedings at  Show Cause Stage. *   Higher Rank, Harsher Punishment Justified: Supreme Court Restores Dismissal  of Bank Manager in Misappropriation Case. *   Limitation for Export Refund to Be Counted from Foreign Exchange Realisation,  Not From Export Invoices Issuance: CESTAT  

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