2025 (9) TMI 933

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.... appellant is engaged in the business of undertaking electrical works and carries out such works with the help of deployment of labour. The appellant reflected the amount received on account of deployment of labour in their balance sheet under the head of "labour charges". The same was also declared in the Income Tax Returns filed by them. 3. On the basis of the information furnished by the appellant in their Income Tax Returns for the period from 2015-16 to 2017-18 (up to June, 2017), the Revenue was of the view that the appellant is liable to pay Service Tax inter alia for the labour charges received by them. 4. Accordingly, a Show Cause Notice dated 12.04.2021 was issued, demanding Service Tax amounting to Rs.8,36,281/- (inclusive ....

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....In view of the above, the Ld. Counsel for the appellant submits that the appellant herein cannot be made liable to pay Service Tax in respect of the charges received for supply of labour. Accordingly, it is prayed that the demand confirmed against the appellant in the impugned order be set aside. 7. On the other hand, the Ld. Authorized Representative of the Revenue reiterates the findings in the impugned order. 8. Heard both sides and perused the appeal records. 9. It is a fact that during the period under dispute, the appellant has supplied labour and received payment, which is reflected in their Balance Sheet under the head of 'labour charges' and in the Income Tax Returns filed by them. On the basis of the above information fur....

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....y :- TABLE Sl. No. Description of a service Percentage of service tax payable by the person providing service Percentage of service tax payable by the person receiving the service 8. in respect of services provided or agreed to be provided by way of supply of manpower for any purpose 25% 75 % • Notification No. 7/2015-S.T., dated 1-3-2015 ..... (B) in the Table,- (i) in column (4), for the column heading, the following column heading shall be substituted with effect from 1st March, 2015, namely :- "Percentage of service tax payable by any person liable for paying service tax other than the service provider"; (ii) ..... (iii) against Sl. No. 8, in c....