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Tcs E-Serve Ltd. (Earlier Known As ... vs A.C.I.T. 9(3), Mumbai on 18 April, 2023

8. We now take up the issue of relating to the classification of Lease Circuit Service. We note that the leased line service has been included under the category "Telecommunication Service" u/s 65(105) (zzzx) of the Act. Consequently, as there is a specific classification for the said service, we hold that this service is not taxable under this category as it has not been provided by "Telegraph Authority". We observe that the Ld Counsel has relied upon the decision of Tribunal Mumbai in the case of TCS E-Serve Ltd. vs. Commissioner of Service Tax, Mumbai 2014 (33) STR 641 (TRI.), wherein this Hon'ble Tribunal has held that International leased circuit service from the foreign vendor was not taxable being telecommunication service from a person other than the telegraph authority. It has also been submitted before us that the demand on this account has been dropped for the subsequent period vide Order-in-Original dated 28.08.2012, we hold that the demand for the previous period cannot be sustained.
Income Tax Appellate Tribunal - Mumbai Cites 10 - Cited by 0 - Full Document

Reliance Ada Group Pvt. Ltd vs Commissioner Of Service Tax on 30 November, 2015

5 ST/766&767/2012  Reliance ADA Group Pvt. Ltd. vs. Commissioner of Service Tax, Mumbai-IV8 He further submitted that the Commissioner had ignored the details of various payments made under the head "Others" provided by the appellant which has been noted in the impugned order. A bare perusal of the activities for which payment had been made, would indicate that the same is liable to be taxed as "Online Information and Data Base Access and Retrieval Services". Learned Counsel further submitted that the intention of Section 66A is to shift the burden of tax from the service provider to the recipient of service. However, these activities take place outside India and therefore, such services are not taxable in the hands of the foreign service providers or in the hands of the appellant. In support of his submission, he relied upon the following decisions:-
Custom, Excise & Service Tax Tribunal Cites 19 - Cited by 2 - Full Document
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