Service tax exemption for services to UNICEF upheld under notifications covering United Nations-linked international organisations.

Services provided to UNICEF were treated as eligible for service tax exemption under Notification No. 16/2002-ST and Notification No. 25/2012-ST because the exemption entry covering services provided to the United Nations and specified international organisations was read broadly enough to include UNICEF. The text notes that earlier Tribunal decisions had already treated UNICEF as within the exemption, and its role as an arm of the United Nations supported that view. The absence of UNICEF's express name in the notification was not accepted as a basis to deny exemption, and the demand was therefore regarded as unsustainable.

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Issues: Whether services provided to UNICEF were eligible for service tax exemption under Notification No. 16/2002-ST dated 02/08/2002 and Notification No. 25/2012-ST dated 20/06/2012.

Analysis: The exemption entry covered services provided to the United Nations for specified international organisations. The Tribunal noted that UNICEF had already been held to fall within the scope of the exemption in earlier Tribunal decisions, and that UNICEF functions as an arm of the United Nations. The view that UNICEF was not specifically named in the service tax notification was rejected, as the relevant entry was held to be broad enough to cover it.

Conclusion: The appellant was entitled to exemption for the services provided to UNICEF under both notifications, and the demand was not sustainable.

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