Levy of service tax on cash calls in joint ventures for oil and...

Levy of service tax on cash calls in joint ventures for oil and gas exploration is addressed by characterising inter-participant cash calls as expense-sharing contributions/investments rather than consideration for taxable service. The analysis treats Public-Private Partnership arrangements as joint ventures operating on a revenue-sharing model, distinguishes the appointed operators expenditure role from non-operators contributions, and treats exploration and development costs as contingent investments (sunk if no discovery). Consequently, cash calls representing a participants share of exploration costs are not service tax-able as consideration for service, with reference to relevant contractual allocation and existing circular guidance.