Reverse-charge service tax on CIF sea freight cannot support proceedings after the underlying levy was invalidated.

Reverse-charge service tax on importers for sea transportation services under CIF contracts had already been invalidated by a binding decision. Proceedings founded on those reverse-charge provisions could not continue; accordingly, the show-cause notice seeking service tax from the importer was quashed and set aside.

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Issues: Whether the show-cause notice seeking service tax from importers on sea transportation services under CIF contracts could survive in view of the binding decision invalidating the reverse-charge levy.

Analysis: The issue was covered by the earlier decision which invalidated the reverse-charge provisions imposing service-tax liability upon importers for sea transportation services in CIF contracts and quashed proceedings founded on those provisions.

Conclusion: The impugned show-cause notice was quashed and set aside.

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