Delivery of goods on hire purchase treated as deemed sale; related finance and documentation charges remain taxable under declared services.

Activities related to delivery of goods under hire purchase or instalment systems are a deemed sale so delivery itself is not service taxable; however, services connected to such delivery-documentation, processing, administrative and lease management charges-are taxable. Financial leases and capital leases qualify when they effect transfer of possession and an option or obligation to purchase, whereas operating leases generally do not. Valuation rules confine the taxable base for the financial service component and permit an abatement applicable only to the interest portion, not to all ancillary charges.

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