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Showing contexts for: data access in Commissioner Of Service Tax Iii Mumbai vs M/S Vodafone India Ltd on 6 May, 2025Matching Fragments
Appeal no. Period of Demand Category and Nature of Findings on Facts of the case in
Dispute Service Impugned Order
The Respondent / AIPL
supplements the functions
of Amadeus, Spain, by
preparing and transmitting
the locally generated travel
related data abroad for
incorporation and
synthesis into their core
data base, so as to enable
the Tour Operators
[operating within India] to
access the information /
data stored in the core
computer system abroad
and to enable Amadeus,
Spain to access
information / data entered
by the Tour operators.
(Impugned Order at pg. 23-
30 of Paperbook Vol I).
There is no dispute that
the consideration for the
service is received by AIPL
in convertible foreign
exchange, from Amadeus
Marketing.
The Respondent/AIPL was
also deemed eligible for
exemption u/s 80HHE
[Deduction of profits from
export of computer
software] and later u/s
10A/10B [deduction of
profits and gains of a
100% Export Oriented
undertaking derived from
export of
articles/things/computer
software] of the Income
Tax Act, 1961.
C.A. No. 571- 01.07.2003 to Rs. 32,88,68,402/- Category III Findings on services rendered by
572/2016 31.03.2008 proposed in SCN for Respondent company amounting
Business Auxiliary
period from to marketing and data processing
Commissioner of 01.07.2003 to Services: Section 65
(105)(zzb) of the Finance (Impugned Order at para 21 – pg.
Service Tax 31.03.2008
47 of Paperbook Vol I)
Delhi IV Act, 1994 – marketing and
(Impugned Order at
v. distributing Services provided by the
pg. 22 of Paperbook
M/S Acquire Respondent company fall outside
Vol I) (Impugned Order at pg. 20
Services Pvt. the scope of BAS
Ltd. OIO confirmed the of Paperbook Vol I)
(Impugned Order at para 22 – pg.
demand of Rs.
48 of Paperbook Vol I)
2,56,05,193/- for
the period April
Appeal no. Period of Demand Category and Nature of Findings on Facts of the case in
Dispute Service Impugned Order
2007 to March 2008 Interglobe Enterprises Information Technology services
established Acquire are provided by the Respondent
(Impugned Order at
Services in India. As per company which are excluded
pg. 22 of Paperbook
the agreement between component of BAS
Vol I)
Interglobe and Galileo
(Impugned Order at para 24, 25 –
Service tax demand International USA, Acquire
pg. 49 of Paperbook Vol I)
on extended period was marketing and
of limitation set distributing the hardware
aside and software to Indian
travel agents to enable Activities of Respondent company
(Impugned Order at them to connect to the fall within the scope of Export of
pg. 52 of Paperbook; Galileo’s host CRS Service Rules, 2005, there is no
OIO at pg. 440 of [Computer Reservation liability of service tax - relied on
Paperbook Vol II) System] in the US. CRS is Paul Merchant
Bifurcation of used for booking tickets to (Impugned Order at para 26 – pg.
demand (OIO at pg. and from across the globe. 50 of Paperbook Vol I)
443 of Paperbook Vol Consideration for the
service is received in India Entire Transaction explained from
II)
by Acquire in foreign Page 393 – Page 396.
currency.
C.A. No. 07/2003-09- Demand of Category III Activities of Respondent company
10885/2016 2007 Rs.2,96,35,979 and fall within the scope of Export of
Business Auxiliary
penalty of Service Rules 2005, there is no
Services: Section 65(19)(ii)
Commissioner of Rs.2,96,35,979 and liability of service tax - relied on Paul
of the Finance Act, 1994 –
Service Tax Rs.1000.- Money Merchant
Advertise and Promote the
Delhi III Transfer and
Money Transfer Service
v. Related Service (Impugned order at para 8, Pp.29-
M/s Transcorp 30 of Paperbook)
International
Ltd.
C.A. No. 2005-06 to Order-in-Original Category III Respondent is providing services to
3692/2017 2011-12 [Pg. confirmed the overseas entities. [Impugned Order
Respondent is providing
D – Synopsis – demand on three at Para 3 – Pg. 6 of the Appeal
Business Auxiliary
Commissioner of Appeal counts: (1) Export of Paperbook]
Services to its foreign
Service Tax Paperbook] Service – Rs.
affiliate [Para 2 of Appeal Services provided by the
Delhi IV 66,96,09,360/-; (2)
at Pg. 15 of the Appeal Respondent qualifies under export
vs. Salary paid to
Paperbook]. of service as per Rule 3 of Export
M/s Nortel Seconded employees
(i) voice mail, data services, audio tax services, video tax services, radio paging;
(ii) fixed telephone services including provision of access to arid use of the public switched telephone network for the transmission and switching of voice, data and video, inbound and outbound telephone service to arid from national and international destinations;
Page 34 of 53(v) provision of call management services for a fee including call waiting, call forwarding, caller identification, three-way calling, call display, call return, call screen, call blocking, automatic call-back, call answer, voice mail, voice menus and video conferencing;
(vi) private network services including provision of wired or wireless telecommunication link between specified points for the exclusive use of the client;
(vii) data transmission services including provision of access to wired or wireless facilities and services specifically designed for efficient transmission of data; and