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/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