Reverse charge service tax requires consideration; no liability arises for overseas services when no remuneration is paid.

Service tax under the reverse charge mechanism was not payable for overseas services where no remuneration or consideration had been paid. The liability to tax depended on payment for the service, and since the amount paid to the foreign provider was nil, the prerequisite for fastening service tax liability was absent. The factual finding on absence of consideration was decisive, and the Revenue's appeal was dismissed.

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Issues: Whether service tax was payable under the reverse charge mechanism when no remuneration or consideration had been paid for the overseas services received.

Analysis: The amount paid to the overseas service provider was admitted to be nil. On that basis, the prerequisite for fastening service tax liability was absent, and the lower authority had not appreciated this factual aspect.

Conclusion: Service tax liability did not arise in the absence of payment of remuneration or consideration, and the Revenue's appeal was dismissed.

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