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ITA No.558/Rjt/2012
ITO vs. Shri Madhukar V. Gupta
AY : 2009-10
Trading, warehousing, research and development services,
computer software services, including information enabled services
such as back-office operations, call centers, content development or
animation, data processing, engineering and design, graphic
information system services, human resources services, insurance
claim processing, legal data bases, medical transcription, payroll,
remote maintenance, revenue accounting, support centers and
web-site services, off-shore banking services, professional services
(excluding legal services and accounting) rental/leasing services
without operators, other business services, courier services, audio-
visual services, construction and related services, distribution
services (excluding retail services), educational services,
environmental services, financial services, hospital services, other
human health services, tourism and travel related services, ,
recreational, cultural and sporting services, entertainment
services, transport services auxiliary to all mo des of transport,
pipelines transport.
"76. The "services" for the purposes of [1] [clause] (z) of section 2 shall be the
following, namely:- Trading, warehousing, research and development services,
computer software services, including information enabled services such as back-
office operations, call centres, content development or animation, data
processing, engineering and design, graphic information system services, human
resources services, insurance claim processing, legal data bases, medical
transcription, payroll, remote maintenance, revenue accounting, support centres
and web-site services, off-shore banking services, professional services (excluding
legal services and accounting) rental/leasing services without operators, other
business services, courier services, audio-visual services, construction and
related services, distribution services (excluding retail services), educational
services, environmental services, financial services, hospital services, other
human health services, tourism and travel related services, recreational, cultural
and sporting services, entertainment services, transport services, services
auxiliary to all modes of transport, pipelines transport.
[1] [Explanation: The expression "trading", for the purposes of the Second
Schedule of the Act, shall mean import for the purposes of re-export.]
From the above, it is amply clear that service includes trading activity if it
related to the import of the goods for the purpose of the export.