III. Indirect Taxes Case Laws:
1. Delhi Transport Corporation Vs. Commissioner Service Tax, CEAC No. 95 of 2014, Date of Decision: 17.04.2015, High Court Of Delhi
• Whether Service Tax burden can be shifted upon other person by contractual agreement?
- Held: Yes
•
Whether the service provider can ask the revenue to collect the tax
from the service receiver with whom service provider has entered into
contractual agreement for payment of service tax by him?
- Held: No
The
appellants were an autonomous body of Govt. of NCT of Delhi created
under the Road Transport Act. The appellants entered into contracts with
agencies (contractors/advertisers) providing space to such parties for
display of advertisements on bus-queue shelters and time-keeping booths.
The agreement provided that it shall be the responsibility of the
contractor/Advertiser to pay direct to the authority and MCD concerned
the advertisement tax or any other taxes levy payable or imposed by any
authority and this amount will be in addition to the license fee quoted.
The Department raised demand of service tax under 'Sale of Advertising
Space or Time Services' and levied penalty for non-registration,
evasion, etc.
Hon’ble
High Court held that it is the appellant who have to discharge the
liability towards the service tax. Undoubtedly, the service tax burden
can be transferred by contractual arrangement to the other party. But,
on account of such contractual arrangement, the assessee cannot ask the
Revenue to recover the tax dues from a third party or wait for discharge
of the liability by the assessee till it has recovered the amount from
its contractors. The condition imposed in the agreement with the
contractor governs the rights and obligations arising out of the
contracts. From such an agreement, DTC would be in a position to recover
the amount of service tax paid by it to the Revenue, from the
contractor. For purposes of the taxing statute, the appellant is an
assessee, and statutorily bound to not only get itself registered but
also submit the requisite returns as per the prescription of law and
rules framed thereunder.
(Please click here for judgment)
2. M/s. Tarsem Mittal & Sons Vs. Commissioner of Central Excise, S. T. A. No. 363 of 2009, Date of Decision: 19.12.2014, CESTAT - New Delhi
Issue: Whether commission received from Western Union is liable to service tax?
Held: No
The
appellant is an agent of Western Union on whose behalf appellant is
disbursing money to the persons directed by Western Union who is located
outside India. Revenue is of the view that as the service has been
performed in India therefore, the service is received by Western Union
in India. Therefore appellant is liable to pay service tax under the
category of Business Auxiliary services for the commission received by
the appellant for disbursing money to a person directed by Western Union
.
Hon’ble
Tribunal relied upon its decision given in the case of Paul Merchant in
which it held that in such a cases since services although performed in
India but the respondent is located outside India and services has been
provided on behalf of the recipient located outside India. Therefore,
it falls under the export of services. In these circumstances, this
Tribunal has held that no service tax is payable by the assessee under
the category of Business Auxiliary services.
(Please click here for judgment)