2025 (1) TMI 538

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....ndent is engaged in providing 'Banking and other Financial Services' through its branches. Based on an intelligence, the enquiry was conducted by the officers of Directorate General of Central Excise Intelligence, Regional Unit Indore, it was observed that the respondent was rendering services for processing of export documents and realization of proceeds by the bank/financial institutions located in non-taxable territory. The respondent was observed liable under Reverse Charge Mechanism to discharge the service tax liability on the said services provided. 2. Accordingly, vide Show Cause Notice No. 73/2016 dated 16.03.2018, the service tax amounting to Rs.43,18,535/- on the total taxable value amounting to Rs.3,36,74,665/- was proposed t....

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.... exporters and there is no dispute about the said charges in this Appeal. The Appellant Bank cannot be said to be the recipient of service for the activities undertaken by the Foreign Banks situated outside India, the charges for which are deducted at source on the export bill. The Appellant Bank merely acts on behalf of the Indian exporter and facilitates the service. The Appellant Bank, therefore, would not be liable to pay service tax under the reverse charge mechanism." 4.1 The present demand is prayed to be set aside based on the said decision. Accordingly, appeal is prayed to be dismissed. 5. Learned Departmental Representative reiterated the findings of Commissioner (Appeals). 6. Having heard both the parties. 7. We obser....