https://www.taxtmi.com/caselaws?id=764973 CESTAT Mumbai held that allocation of head office expenses by UK parent to Indian branches does not constitute taxable service under Finance Act 1994. For period prior to 01.05.2011, business support services were not within tax scope. Post 01.07.2012, no service element existed as expenses were mere reimbursements without service agreement. Department failed to identify service provider or establish service relationship. Mere expense allocation based on revenue/headcount parameters cannot be treated as consideration for services. Income tax deduction under Section 44C does not create service tax liability. Following precedents in Tech Mahindra and Steel Authority cases, tribunal concluded expense sharing between associated enterprises is not taxable service. Revenue appeal dismissed. en-us Mon, 20 Jan 2025 00:00:00 +0530 Wed, 22 Jan 2025 12:40:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764973 CESTAT Mumbai held that allocation of head office expenses by UK parent to Indian branches does not constitute taxable service under Finance Act 1994. For period prior to 01.05.2011, business support services were not within tax scope. Post 01.07.2012, no service element existed as expenses were mere reimbursements without service agreement. Department failed to identify service provider or establish service relationship. Mere expense allocation based on revenue/headcount parameters cannot be treated as consideration for services. Income tax deduction under Section 44C does not create service tax liability. Following precedents in Tech Mahindra and Steel Authority cases, tribunal concluded expense sharing between associated enterprises is not taxable service. Revenue appeal dismissed. Case-Laws Service Tax Mon, 20 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764973