TaxTMI 
TaxTMI 
2024 (10) TMI 895
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....nsing International Inc.USA when the service provider located in abroad having office in India. 2. Shri G Thangaraj learned Counsel appearing on behalf of the appellant at the outset submits that there is no dispute that the agreement for receiving intellectual property service is between the Monogram Licensing International Inc. and the appellant. However, there is not dispute that the service provider has establishment in India at the address the Millienia, Level 6, Tower B, 1&2 Murphy road, Ulsoor, Bangalore 560008. He submits that even the agreement though made between the appellant and Monogram Licensing International Inc. USA but the same was signed on behalf of the service provider by the Chief Financial Officer who is placed at the....
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....their establishment office at Bangalore, in this position, it is necessary to record to Section 66A and Rule 2(1) D4 under which the assessee is require to pay service tax under reverse charge mechanism : - "66A. Charge of service tax on services received from outside India. (1) Where any service specified in clause (105) of section 65 is,- (a) provided or to be provided by a person who has established a business or has a fixed establishment from which the service is provided or to be provided or has his permanent address or usual place of residence, in a country other than India, and (b) received by a person (hereinafter referred to as the recipient) who has his place of business, fixed establishment, permanent address or usual pla....