Chartered Accountant
Bookmark and Share
click here to subscribe our newsletter
 
 
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.  

Comments

Print   |    |  Comment

PJ/Case Law/2013-14/1841

Service tax credit on outward transportation is admissible only if freight forms part of price.

Case:- M/s NICCO CORPORATION LTD VERSUS COMMISSIONER OF SERVICE TAX, KOLKATA

Citation:-2013-TIOL-190-CESTAT-KOL

Brief Facts:-Applicant filed this application for waiver of amount of Service Tax, interest and penalty. The demand of Service Tax of Rs.3,57,801/- is confirmed after denying credit of Service Tax paid on outward transportation of the goods. The demand of Rs.54,01,842/- is confirmed on the ground that the applicant has undertaken the activity which is covered under Business Auxiliary Service and are liable for Service Tax. Another demand of Rs.22,85,484/- in respect of activity of erection and commissioning.

Appellant Contentions:-The contention of applicant in respect of the demand of Rs.3,57,801/- is that applicant has rightly taken credit in respect of the Service Tax on outward transportation. The cost of outward transportation is part of the price. The applicant relied upon the Board Circular dated 23/08/2007 whereby it has been clarified that in case the outward freight is part of price, the credit of service tax paid in this regard is admissible. In view of this the contention is that the applicants are entitled for credit of service tax paid in respect of outward transportation of the goods.

In respect of the demand of Rs.54,01,842/-, the contention is that the period in dispute is 10/9/2004 to 31/3/2006 and the definition of business auxiliary service was amended with effect from 16/6/2005. Prior to 16/6/2005, business auxiliary service includes production of goods on behalf of the client and after 16/6/2005, the definition is amended to the effect that business auxiliary service means production of goods for, or on behalf of the client. In view of this amendment, the applicants are liable to pay service tax with effect from 16/06/2005 in respect of business auxiliary service undertaken by them. It is also submitted that the applicants are undertaking processing in respect of gems and diamonds which is exempt from service tax by Notification No.21/05-ST dated 7/6/05. In respect of the demand of Rs.22,85,484/-, the contention is that applicants undertaken the activity of laying the cables and as per Board Circular No.123/05-10 TRU dated 24/5/10 whereby it has been clarified that activity of laying the cable is not taxable under the Service Tax Rules for service tax.
 
Respondent Contentions:-Respondent submitted that in respect of the demand of Rs.3,57,801/- that though the applicant has taken the plea that the outward freight is part of price but there is no evidence on record to show that the same is part of the price. It is also submitted that this plea was not taken before the adjudicating authority nor in the present grounds of appeal therefore the applicants want to make a new case which is not permissible under law.

In respect of the demand of Rs.54,01,842/-, the contention of Revenue is that before the adjudicating authority in reply to show cause notice, the applicants admitted the taxability of the service and claimed the benefit of Notification No.21/05-ST dated 7/6/05. Even in the taxability of service was not challenged in the present appeal also. Therefore, the plea of the applicant that prior to 16/6/05, the activity of the applicants are not covered under Service Tax has no merit. In respect of the demand of Rs.22,85,484/-, the demand is confirmed by treating the activity undertaken by the applicant is erection and commissioning. Now the applicant has taken a new plea which was not before the adjudicating authority. The case before the adjudicating authority was that the contract was for works contract and relied upon the decision of the Tribunal in the case of Daelim Industrial Co Vs. Commissioner - 2003 (155) ELT 457 (Tribunal) = 2003-TIOL-110-CESTAT-DEL .The contention of Revenue is that the above decision is overruled by the Larger Bench in the case of Commissioner of Central Excise, Raipur Vs. BSBK Pvt Ltd - 2010 (253) ELT 522 (Tn. LB) = 2010-TIOL-646-CESTAT-DEL-LB .

The Revenue also relied upon the Hon'ble Andhra Pradesh High Court's decision in the case of Commissioner of Central Excise, Guntur Vs. Shri Chaitanya Educational Committee - 2011 (22) STR 135 (A.P) = 2011-TIOL-147-HC-AP-ST whereby the Hon'ble High Court laid the principles to be taken into consideration while deciding the stay or dispensing with the requirement of pre-deposit under Section 35 of the Central Excise Act.
 
Reasoning of Judgment:-We find that the demand of Rs.3,57,801/- is confirmed after denying the credit in respect of the service tax paid on outward transportation. During arguments a specific query is made by the Bench, whether outward freight is part of the price of the goods on which duty has been paid, Ld. Counsel submitted that the same is part of the price. However, no evidence by way of producing any document in support of the claim. The Board Circular which was considered by the Hon'ble Punjab & Haryana High Court in the case of Ambuja Cements Ltd Vs. UOI - 2009 (236) ELT 431 (P&H) = 2009-TIOL-110-HC-P&H-ST where it has been clarified that credit in respect of Service Tax on outward transportation is admissible if the freight is part of price. In absence of any evidence to show that the freight is part of the price, we find that applicant had not made out a case for total waiver of the demand in this regard.

In respect of the demand of Rs.54,01,842/- it is confirmed on the ground that the applicant undertaken the activity which is covered under the scope of business auxiliary service. The applicant admitted during argument that from 16/6/05 the applicants are liable to pay Service Tax as provider of business auxiliary service. Further we find that the taxability of the service was not before the adjudicating authority. The applicant admitted that the service undertaken by applicant is liable for service tax however claimed the benefit of Notification No.8/05. The applicant during arguments submitted that even after 16/6/05, the applicants are entitled for benefit of Notification No.21/05-ST dated 7/06/2005 which exempts the activity in respect of gems and diamond. From the record we find that the applicants are also undertaking the activity in respect of other goods also such as petrdidish, dental powder, medical equipments, semi-conductors, irradiation of 0 ring, LDPE Gaskets etc and these items are not covered under the Notification No.21/05-ST. In these circumstances, we find that the applicant has not made out a total waiver of demand in this regard.

In respect of the demand of Rs.22,85,484/- which is confirmed by treating the activity undertaken by applicant as erection and commission. We have gone through the contracts. The contracts are for laying the cables and the Board vide Circular dated 24/5/10 clarified that laying of cables are not liable to service tax. No doubt, this plea was not taken before the adjudicating authority but on the facts of the case in respect of the activity of laying cables, prima facie, the applicant has a strong case on this issue.

In view of the above discussion, as we held that applicant has not made out a case for total waiver of service tax in respect of the demand of Rs.3,57,801/- and Rs.54,01,842/- after taking into consideration the facts and circumstances of the case and the guidelines laid down by the Hon'ble High Court in the case of Shri Chaitanya Educational Committee (supra), the applicants are directed to deposit a total amount of Rs.31,00,000/- (Rupees Thirty One Lakhs only) within a period of eight weeks. On deposit of the above amount, pre-deposit of remaining amount of Service Tax, interest and penalty are waived during pendency of the appeal and report compliance on 23rd of January, 2012.
 
Decision:-Stay application disposed of.

Comment:-The stay application was partly allowed only due to the fact that a part of the demand raised under the category of Errection and commission pertained to laying of cables that was exempt vide board circular.

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