Statutory levies collected from plot-holders were treated as non-taxable service consideration under the industrial estate framework.

Transfer fees and miscellaneous charges collected from plot-holders, including floating charges, administration charges and the share of the infrastructure up-gradation fund, were treated as statutory levies under the industrial estate framework rather than consideration for any taxable service. The share of the infrastructure up-gradation fund, collected on behalf of industrial associations and reimbursed to them, was also found not to amount to service consideration. The issue was treated as already covered by the corporation's earlier case and as no longer res integra, so the charges were held not liable to service tax.

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Issues: Whether transfer fees and miscellaneous charges, including floating charges, administration charges and the share of infrastructure up-gradation fund collected by the industrial development corporation from plot-holders, were liable to service tax.

Analysis: The charges were treated as statutory levies collected under the framework governing the industrial estate, and not as discretionary amounts for any service rendered by the corporation. The share of infrastructure up-gradation fund collected on behalf of industrial associations and reimbursed to them was also found not to constitute consideration for service. The controversy was held to be covered by the earlier decision in the corporation's own case and the matter was treated as no longer res integra.

Conclusion: The charges were held not liable to service tax, and the appeal succeeded.

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