https://www.taxtmi.com/caselaws?id=787496 The note addresses whether service tax applies to Protection & Indemnity (P&I) fees paid to Steamship Mutual Underwriting Association (Bermuda) Ltd, focusing on mutuality and the scope of Explanation 3 to Section 65B(44). It records that Explanation 3 was not pleaded in the show-cause notice and the Revenue failed to prove the P&I club was an unincorporated association or a taxable "body of persons." Documentary evidence showed the club's statutory incorporation and characterization of payments as mutual premiums. Applying the Calcutta Club construction, the piece concludes that services within genuine mutuality by an incorporated club fall outside service-tax liability, so the demand cannot be sustained. en-us Wed, 04 Mar 2026 00:00:00 +0530 Sat, 07 Mar 2026 08:39:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787496 The note addresses whether service tax applies to Protection & Indemnity (P&I) fees paid to Steamship Mutual Underwriting Association (Bermuda) Ltd, focusing on mutuality and the scope of Explanation 3 to Section 65B(44). It records that Explanation 3 was not pleaded in the show-cause notice and the Revenue failed to prove the P&I club was an unincorporated association or a taxable "body of persons." Documentary evidence showed the club's statutory incorporation and characterization of payments as mutual premiums. Applying the Calcutta Club construction, the piece concludes that services within genuine mutuality by an incorporated club fall outside service-tax liability, so the demand cannot be sustained. Case-Laws Service Tax Wed, 04 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787496