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<h1>Rule 2(1)(d)(iv) cannot create tax liability without statutory authorization; service tax on import before 18-4-2006 unsustainable under s65(105) Explanation</h1> <h3>Union of India Versus Indian National Shipowners Association</h3> SC dismissed the appeal, upholding the HC's finding that Rule 2(1)(d)(iv) cannot create a tax liability absent statutory authorization. The Court held ... Demand of service tax - Import of service tax - Supreme Court dismissed appeal where High Court [2008 (12) TMI 41 - BOMBAY HIGH COURT] held that Provisions of Rule 2(1)(d)(iv) can not create any tax liability which is not authorized by law. Before insertion of section 66A with effect from 18-4-2006, there was no authority to levy service tax on Import of service. Explanation below section 65(105) did not give any authority to levy service tax on import of services. The Supreme Court of India dismissed the special leave petition in the case. Justices S.H. Kapadia and Aftab Alam were presiding. Counsels included Mr. Mohan Parasaran, Mr. Harish N. Salve, and others.