No Service Tax on Mining Rights Payments Before April 1, 2016 Under Point of Taxation Rules Section

The SC dismissed the appeal, affirming that service tax is not payable on amounts paid for the right to use natural resources from allotted mines when agreements were executed before April 1, 2016. The Court upheld CESTAT's finding that the point of taxation rules and reverse charge mechanism apply only from the date the activity became taxable. Since the mining rights agreements predated this, no service tax liability arose.

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The Supreme Court of India dismissed the Civil Appeal as they found no grounds to interfere with the impugned Order dated 09-05-2023 passed by the Customs, Excise and Service Tax Appellate Tribunal, New Delhi, Principal Bench in Service Tax Appeal No. 54002/2018.

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