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AI Drafter

Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required


Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

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        Case ID :

        SC dismisses plea of Pvt tour operators seeking exemption from GST for Haj, Umrah tours

        July 26, 2022

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        New Delhi, Jul 26 (PTI) The Supreme Court Tuesday dismissed a batch of petitions filed by various private tour operators seeking exemption from the Goods and Services Tax (GST) for the Haj and Umrah tours offered by them.

        The petitions seeking exemption had alleged discrimination against the pilgrims travelling to Saudi Arabia.

        A bench comprising Justices A M Khanwilkar, A S Oka, and C T Ravikumar dismissed the petitions on both the grounds of exemption and discrimination.

        The bench said that the argument raised by the petitioners regarding the extra-territorial application of GST for services given outside India is kept open, as it is pending consideration before another bench.

        The tour operators had challenged the levy of GST on Hajis who avail themselves of services offered by registered private tour operators because no tax law can be applicable on extra-territorial activities as per Article 245 of the Constitution.

        The petitions argued that the services consumed outside India cannot be subjected to GST and that the levy is discriminatory as it exempts certain hajis who undertake the pilgrimage through the Haj Committee of India.

        GST applicability to overseas pilgrimage services questioned, with discrimination and extra territoriality issues remaining under judicial consideration. Challenge to the imposition of GST on Haj and Umrah tour services asserted that Article 245 bars extra territorial application of tax law and that services consumed outside India cannot be taxed, and that differential treatment exists because the Haj Committee's arrangements are exempt while private tour operators' services are taxed; the court addressed exemption and discrimination arguments and left the extra territorial question for separate judicial consideration.
                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.

                                GST applicability to overseas pilgrimage services questioned, with discrimination and extra territoriality issues remaining under judicial consideration.

                                Challenge to the imposition of GST on Haj and Umrah tour services asserted that Article 245 bars extra territorial application of tax law and that services consumed outside India cannot be taxed, and that differential treatment exists because the Haj Committee's arrangements are exempt while private tour operators' services are taxed; the court addressed exemption and discrimination arguments and left the extra territorial question for separate judicial consideration.





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