2024 (2) TMI 962

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.... demanding service tax under the category of management and business consultant service and credit card, debit card, charge card or other payment card services which are under negative list of services after 01.07.2012. 2. The issue in all the three appeals is common, therefore, all are being decided by a common order. 3. The facts of the case are that during the period 2011-12 and 2012-13, the appellants were appointed by Tripura Gramin Bank as business correspondent for disbursal up to 100 days of wages to the unskilled rural labours as a measure of employment generation under Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA) as per RBI Circular. The appellants are engaged in the ancillary works of bank in rural service. ....

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....ed under Notification No.25/2012-ST Serial No.29 (g) dated 20.06.2012. Therefore, they are not liable to pay service tax. 5. On the other hand, the ld.A.R. for the Revenue supported the impugned order. 6. Heard the parties and considered the submissions. 7. We find that the appellants were appointed by Tripura Gramin Bank for disbursal up to 100 days of wages to the unskilled rural labours as a measure of employment generation under Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA) as per RBI Circular. 8. The "taxable service" by a management or business consultant service has been defined under Section 65 (105) (r) of the Finance Act, 1994, which is as under : "Management or business Consultant" means any person who is....