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/2013-14/1875

Whether penalty under section 76 and 78 imposable when credit was utilised without complying with restriction of 35%?

Case:-VODAFONE DIGILINK LTD. VERSUS COMMISSIONER OF CENTRAL EXCISE, JAIPUR-II

Citation:-2013(29) S.T.R. 229 (Raj.)

Brief Facts:-Appeal has been preferred under Section 35G of the Central Excise Act, 1944 as against order dated 28-6-2011 passed by the Customs, Excise & Service Tax Appellate Tribunal, New Delhi (in short, ‘the Tribunal’) in Appeal No. ST/246/2008-CU [DB] [2011 (24)S.T.R. 562 (Tri.-Del.)].

Appellant was inter alia engaged in providing cellular telephone service in Jaipur Circle. It was registered and paying service tax under ‘telephone services’. Appellant was receiving various input services and availing Service Tax credit on the same in terms of Service Tax Credit Rules, 2002 (hereinafter referred to as ‘the Rules of 2002’). The appellant was also receiving roaming (National & International) charges from other telecom operators. Roaming charges were paid by the home operator (telecom operator with whom the subscriber is registered) to the service operator (telecom operator whose network the subscriber of the home operator is visiting). Thus, the appellant has received roaming charges from various other operators towards roaming facility provided by the former to the subscribers of the latter while on visit to Jaipur Circle. The appellant was not paying service tax on roaming charges received from other operators during the period of dispute i.e. May 2003 to August 2004. The appellant was of the view that Rule 3(5) of the Rules of 2002 was not applicable to it because the appellant was not providing exempted service or non-taxable service. Thus, the appellant was utilizing the Service Tax credit availed on various input services for payment of service tax on output telephone service without any restriction of 35% specified in Rule 3(5) of the Rules of 2002.

A show cause notice was issued on 21-8-2006 proposing to recover service tax of Rs. 39,41,384/- on the ground that the appellant should have restricted utilization of Cenvat credit towards payment of output service tax in terms of Rule 3(3)/3(5) of the Rules of 2002. Reply to the show cause notice was given on 22-11-2006. Appellant appeared before the Additional Commissioner for personal hearing. The Additional Commissioner passed order on 3-4-2007 confirming the demand of service tax of Rs. 35,99,882/- for the aforesaid period on the ground that the roaming charges were received by the appellant for providing non-taxable service. The Additional Commissioner has also imposed penalties and ordered for recovery of interest. Appeal was preferred as against the order before the Commissioner (Appeals). Commissioner (Appeals) confirmed the order passed by Additional Commissioner. Aggrieved thereby, appeal was filed before the Tribunal. The Tribunal has remanded the case to the original authority for re-quantification of demand after considering the excess/short utilization of credit in each half yearly return period, instead of monthly basis. So far as restriction of Cenvat credit to the extent of 35% was concerned, it was not disputed being covered by virtue of decision of the Tribunal in Idea Cellular Ltd. v. Commissioner of Central Excise, Rohtak, 2009 (16)S.T.R. 712 (Tri.-Del.). Visiting network service is exempted for which admissibility of Cenvat credit shall be limited to 35% in respect of each return period when Cenvat credit is claimed for set off. Accordingly, liability of the appellant was ordered to be recalculated giving set off on Cenvat credit limiting to 35% in respect of each return period. The Tribunal accordingly held that the adjudication shall end in re-computing service tax demand. The Tribunal has relied upon the decision in Idea Cellular Ltd. case (supra). However for the issue of extended period along with interest and penalty, the Tribunal has confirmed the invocation of extended period of limitation and upheld the penalty imposed under Section 76 of the Finance Act, 1994 (hereinafter referred to as “the Act of 1994”) and so far penalty under Section 78 of the Act of 1994 is concerned, that has been ordered to be limited to the quantum of tax payable upon re-computation as directed by the Tribunal. However, the authority was directed to examine whether concession in penalty is permissible under second proviso to Section 78 of the Act of 1994. Appeal has been allowed to the aforesaid extent.
 
Appellant Contentions:-Appellant has submitted that in the instant case provision of limitation as contained in proviso to sub-section (1) of Section 73 could not have been invoked. It could not be said to be a case of deliberate suppression; mere omission to give correct information is not suppression of fact unless it was deliberate to stop the payment of duty. ‘Suppression’ means failure to disclose full information with the intent to evade payment of duty. Hence, penalty could not have been imposed. Thus, the impugned order is bad in law. However, learned counsel has submitted that the issue of taxability in the instant case stands settled by the decision of the Tribunal in the case of Idea Cellular Ltd. (supra), that part of the order has not been questioned; penalty part has been questioned.
 
Reasoning of Judgment:-After hearing learned counsel for the appellant at length, it is clear that in case the service provider opts not to maintain separate accounts of inputs service meant for consumption in relation to rendering of such services which are chargeable to service tax as well as exempted services or non-taxable services, he shall be allowed to utilize service tax credit for payment of service tax on any output service only to the extent of an amount not exceeding 35% of the amount of service tax payable on such output service. Since the appellant was providing taxable as well as non-taxable services, utilization of service tax credit was thus restricted to 35% of service tax payable. The adjudicating authority has reduced the demand of service tax of Rs. 3,41,502/- as interconnecting usage charges were not taxable for the period August 2002 to April 2003. During the period 16-8-2002 to 13-5-2003, interconnecting usage charges were not exempted service and the appellant was eligible for utilizing Cenvat credit without restriction of 35%. The plea of appellant is not sustainable for the remaining period. It is apparent that the appellant has wilfully suppressed the facts of availment of Cenvat credit in respect of exempted service in excess of the prescribed limit. When limit was prescribed, facts ought to have been mentioned clearly. When exempted service was availed in excess of the prescribed limit, it was incumbent upon the appellant to disclose it. The appellant is a professionally managed corporate. Thus, it has been rightly held that the case is covered under proviso to sub-section (1) of Section 73 of the Act of 1994 which provides that where any service tax has not been levied or paid or has been short-levied or short-paid or erroneously refunded by reason of (a) fraud; or (b) collusion; or (c) wilful mis-statement; or (d) suppression of facts; or (e) contravention of any of the provisions of the Chapter or of the Rules made thereunder with intent to evade payment of service tax, by the person chargeable with the service tax or his agent, the provisions of this sub-section shall have effect, as if, for the words “one year”, the words “five years” had been substituted, so as to initiate the proceedings to pay the amount specified in a notice. Thus, service of notice within five years from the relevant date is sustainable in law. It is apparent that excess credit was utilized by the appellant to the extent of Rs. 35,99,882/- from May 2003 to August 2004. Finding has been recorded by the Additional Commissioner that the assessee has contravened the provisions of Section 68 of the Act read with Rule 6 of Service Tax Rules, 1994 and Rules 3 and 4 of the Rules of 2002 by such wrongful availment and utilization of Cenvat credit. Therefore, the assessee is liable for penalty under Sections 76 and 78 of the Act of 1994 read with Rule 6 of the Rules of 2002 for fraudulent/wrongful availment and utilization of CENVAT credit.

Rule 3(5) of the Rules of 2002, as existed during the relevant period, provided that, “in case the service provider, opts not to maintain separate accounts of inputs service meant for consumption in relation to rendering of such output services which are chargeable to service tax as well as exempted services or non-taxable services, he shall be allowed to utilize service tax credit for payment of service tax on any output service only to the extent of an amount not exceeding thirty five per cent of the amount of service tax payable on such output service”. The appellant was providing taxable and non-taxable services, therefore the utilization of credit was restricted to 35% of the service tax payable. It is apparent that the assessee has suppressed the facts of availment of Cenvat credit for exempted or non-taxable services. It is clear that the case is covered by Rule 3(5) of the Rules of 2002. Finding recorded by the Additional Commissioner as to wilful suppression has been confirmed by the Commissioner (Appeals) as well as the Tribunal. On facts, it appears to be a case of suppression.

It is apparent that Cenvat credit of higher amount was unduly claimed; it was nowhere disclosed in the return. There was failure to make disclosure of the availment of the credit in excess and entire facts were not mentioned in various returns. Thus, it has been held to be a case of wilful suppression. Finding recorded by the Tribunal in para 7 of its order is quoted below :

“7.So far as levy of penalty is concerned the case of the appellant is that Cenvat credit of a higher amount was unduly claimed. Sample copy of the return is available in appeal folder at page 23 of the paper book. That nowhere discloses bona fide of the appellant. Had the appellant disclosed that it was under bona fide belief that service provided by the appellants as visiting network service provider was exempt and not taxable, the appellant would have clearly guided the department to understand its claim on set off Cenvat credit. Failure to make such disclosure in return or submitting entire fact by any letter accompanying its return appears to be a case of wilful suppression.Suppression does not vanish by mere passage of time to issue of show cause notice and contravention of law gets no immunity from penal consequences. Suppression corroborated by an untrue declaration in the return filed calls for levy of penalty. When the return contains a declaration as to the self assessment particulars stating that the assessee had paid service tax correctly in terms of provisions of the Act and Rules made thereunder such declaration becomes faulty in absence of bona fide statement either on the return or made through a letter accompanying the return. Once the appellant has claimed that service tax has been paid in accordance with the law and this is not paid, that imputes the appellant to the charge. Such view brings harmony in construction of law and for effective implementation thereof in respect of self assessment procedure. The act of false declaration can be remedied by levy of penalty. Thus penalty levied under Section 76 is confirmed and so far as penalty under Section 78 is concerned that shall be limited to the quantum of tax payable upon re-computation as directed aforesaid. However, the authority shall examine whether concession in penalty is permissible under second proviso to section 78 of the Act. Interest as required under Section 75 shall be payable on the tax due.”
 
We agree with the aforesaid findings recorded as to suppression of facts.

Counsel for the appellant has relied upon decision of Hon’ble Supreme Court in Continental Foundation Jt. Ventura v. Commr. of C.Ex., Chandigarh-I - 2007 (216)E.L.T. 177 (S.C.) in which expression “suppression” has been considered thus :

“10.The expression “suppression” has been used in the proviso to Section 11A of the Act accompanied by very strong words as ‘fraud’ or “collusion” and, therefore, has to be construed strictly. Mere omission to give correct information is not suppression of facts unless it was deliberate to stop the payment of duty. Suppression means failure to disclose full information with the intent to evade payment of duty, when the facts are known to both the parties, omission by one party to do what he might have done would not render it suppression. When the Revenue invokes the extended period of limitation under Section 11A the burden is cast upon it to prove suppression of fact. An incorrect statement cannot be equated with a wilful misstatement. The latter implies making of an incorrect statement with the knowledge that the statement was not correct.”

It was not a case of mere omission to give correct information; it was devised deliberately so to evade tax liability. The limit of exemption was known and provisions of Rule 3(5) of the Rules of 2002 are clear. Thus, it was deliberate suppression of facts. Even testing on the anvil of the aforesaid decision, we find the finding of suppression which has been recorded by the Additional Commissioner and confirmed by Commissioner (Appeals) as well as the Tribunal call for no interference. We find that five years’ period of limitation has been rightly invoked in the instant case. We thus find no ground to interfere in the impugned orders. No substantial question of law is involved in the appeal.
 
Decision:-Appeal dismissed.

Comment:-The essence of this case is that extended period of limitation is invokable and consequently penalty under section 76 & 78 is also imposable when the assessee utilised the credit without complying with the restriction of 35% under the earlier Cenvat Credit Rules, 2002 as it under self assessment, the assessee is expected to correctly assess and disclose its tax liability and non-declaration of complete information in the return amounts to suppression of facts.
 

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