Member subscriptions alone do not trigger club or association service tax under Section 65; Revenue's challenge failed.

Mere collection of subscription from members does not, by itself, bring a federation within the service-taxable category of club or association under Section 65 of the Finance Act, 1994. The HC noted that the issue had already been decided against the Revenue in binding precedent and was no longer res integra, so the Revenue could not tax the respondent-federation solely on the basis of member subscriptions. The appeal was rejected.

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Issues: Whether mere collection of subscription from members by a federation brings it within the service-taxable category of club or association under Section 65 of the Finance Act, 1994.

Analysis: The appeal challenged the Tribunal's view that member subscription, by itself, does not attract service tax under the club or association service definition. The Court noted that the same question had already been decided against the Revenue in earlier binding precedent, and that the issue was no longer res integra. The Court therefore declined to accept the Revenue's attempt to bring the respondent-federation within the taxing provision merely because it collected subscriptions from its members.

Conclusion: Mere collection of subscription from members does not, by itself, make the federation liable to service tax as a club or association under Section 65 of the Finance Act, 1994. The appeal was rejected.

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