Subsidiary of the client has issued Bonds in foreign country. The proceeds of the issue has been utilised by the subsidiary. Further, repayment of the proceeds has been made by the subsidiary.
Service Tax Department is telling the Holding company to pay Service Tax under Full Reverse Charge on Issue related expenses. Contention of the Department is that as the guarantor is holding company, service tax has to be paid by the holding company.
Whether holding company is liable to pay Service Tax?
TaxTMI