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4. Having heard learned counsel and having perused the Appeal Papers, we decline indulgence in the matter agreeing with the views of learned Single Judge in the light of following discussion:
4.1 A BRIEF HISTORY OF SERVICE TAX:
(a) The Finance Act, 1994 for the first time introduced levy of Service Tax w.e.f. 1.7.1994. This statute was structured on the recommendation of Raja Challaiah Committee on Tax Reforms, 1991. "....The source of concept of Service Tax lies in economics. It is an economic concept. It has evolved on account of Service Industry becoming a major contributor to the GDP of an economy, particularly knowledge-based economy.... as an economic concept, there is no distinction between the consumption of goods and consumption of services as both satisfy human needs. ... it is important to note that service tax is a value added tax which in turn is a general tax which applies to all commercial activities involving production of goods and provision of services. ..." observed the Apex Court in ALL INDIA FEDERATION OF TAX PRACTIONERS vs. UNION OF INDIA3.