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M/S Glyph International Ltd. vs Union Of India on 20 February, 2014

23. On the issue of demand of service tax on the consideration received from BSNL, learned Advocate has argued mainly that they were only engaged in printing bill at the premises of BSNL in terms of agreement between BSNL and relied on the judgment of the coordinate bench at Chandigarh in the case of Xerox India Ltd (supra), wherein the Tribunal examined the leviability of service tax under the category of BSS or BAS or under WCS. In the present facts of the case, it is not alleged that they were engaged in either maintenance or repair service or WCS and the only ground was that they have provided BAS to BSNL on which service tax has not been discharged. Learned Special Counsel for the Revenue submitted that it is not a simple case of merely printing the bills rather it is a case of detailed activities carried out by them, as explained in the OIO. The Adjudicating Authority has examined the agreement dt.18.04.2007 and, inter alia, observed that the agreement required the appellant to provide software for designing the various bill formats, which was required to be developed by the bidder free of cost, apart from installing and maintaining the printing system in BSNL Kolkapur's TRA unit premises. The Adjudicating Authority's views on this issue are stated at Para 27.7 of the OIO dt.28.08.2012, cited below for ease of reference:-
Supreme Court - Daily Orders Cites 0 - Cited by 11 - Full Document

Indian National Shipowners Assn. vs Union Of India . on 27 January, 2016

19. Therefore, the short issue is whether the plain reading of the provisions under section 66A read with Rule 3(1)(iii) of TSPOI Rules, 2006, requires that not only services should be received in India but should also be consumed in India for it to become covered by the deeming provision for the purpose of charging service tax on RCM or otherwise. There is no dispute about legality of section 66A for the period post its introduction, as has been held by Hon'ble High Court of Bombay in Indian National Shipowners Association Vs UOI (supra) as well as by Hon'ble Allahabad High Court in the case of Glyph International Ltd Vs UOI (supra). The issue before the Hon'ble High Courts was whether recipient of service in India is liable to service tax from abroad before 18.04.2006 or only after the said date after enactment of section 66A. The Hon'ble Bombay High Court held that service tax can be charged only after the enactment of section 66A, which was upheld by Hon'ble Supreme Court, whereas, charging of service tax on similar service for the period prior to the enactment of section 66A was set aside.
Supreme Court - Daily Orders Cites 0 - Cited by 70 - Full Document

All India Federation Of Tax ... vs Union Of India & Ors on 21 August, 2007

Further, he has also relied on the Hon'ble Supreme Court's decision in the case of All India Federation of Tax Practitioners Vs UOI [2007 (7) STR 625 (SC)] to come to the conclusion that section 66A does not suffer from the vice of unconstitutionality, either on the ground of lack of legislative competence, or on the ground of extra territorial operation of laws. Thus, the basic defence taken by the appellant that no service tax can be levied on the services rendered and consumed abroad will not hold good in view of the deeming provisions created by constitution under section 66A of the Finance Act, 1994.
Supreme Court of India Cites 49 - Cited by 277 - Full Document

Temenos India Pvt Ltd vs Cst Ch - Iii on 6 February, 2020

In the case of M/s Cords Cable Industries Ltd Vs CCGST & ST, Rajasthan, vide Final Order No. 59868/2024 dt.11.12.2024, the Delhi Tribunal, relying on the judgment in the case of The Board of Control for Cricket in India Vs CST, Mumbai-II [2018-TIOL- 2641-CESTAT-Mum], held that the plea of revenue neutrality cannot be accepted as it would make the entire scheme of RCM futile. We, therefore, find that the ground of revenue neutrality taken by the appellant is not sustainable in view of catena of judgments cited by the Revenue and respectfully following the same, we do not consider this ground as tenable for dropping the demand when it is otherwise chargeable to service tax in terms of section 66A on merit.
Custom, Excise & Service Tax Tribunal Cites 10 - Cited by 1 - Full Document
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