TaxTMI 
TaxTMI 
TaxTMI 
2025 (10) TMI 1270
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.... Techno Electric and Engineering Company Limited (hereinafter referred to as 'the appellant-company') is a Public Limited Company registered under the Companies Act, 1956 and is also a Company within the meaning of the Companies Act, 2013 having its corporate office situated at 1B, Park Plaza, 71, Park Street, Kolkata - 700016. The appellant has been engaged in execution of EPC contracts for setting up of Power Plants across India. For handling the various projects across India, it maintains location wise project sites and accordingly, for Service Tax compliance, it obtained multiple Service Tax Registrations bearing Nos. AAJCS4414QSD001 to AAJCS4414QSD093 in various States in India for provision of Works Contract Service, Maintenance and Repair Service, etc. 2.1. The appellant-company, since its inception has been engaged in the execution of turnkey contracts for setting up of Power Plants for various Electricity Distribution Authorities (EDAs) being public utilities. The Customers (EDAs) of the appellant invite Tenders wherein they seek separate itemized quotations in the Tender for (i) supply of equipment/spares and for (ii) rendition of Services. Further, i....
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....ent are inter-state purchases. Such sale is a Sale in Transit. The manufacturer of equipments raises invoices on the Appellant and not on the contractees. The Lorry Receipt/Goods Receipts were also in the name of the appellant. The appellant endorses the Lorry Receipts/Goods Receipts in the name of the contractees during transit of the said equipments before the delivery of equipment at the site of the contractees. 2.8. The above referred purchase and sale of equipment are against E-1 Forms under Section 6(2) of the Central Sales Tax Act. In such case, the first sale i.e., between the seller of the equipment and the appellant would be taxable and leviable to Central Sales Tax and the subsequent sale from the appellant to the customers, would be leviable to tax but exempted from making payment on production of the aforesaid Forms. 2.9. The appellant issues Form C to the seller of the equipment and the seller issues declaration in Form E-1 to the appellant. During sale of equipment by the appellant to the customer, the customer issues Form C to the Appellant. The appellant has duly included above sales in its respective Sales Tax Returns. 2.10. In case of purchase and sale o....
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....e Equipment sold under the Contract of Supply shall be fully insured against loss or damage incidental to manufacture and transportation. Further, in case of goods, the insurance shall be at least for an amount equal to 110% of the cost of the goods. 2.17. The standard practice adopted by the appellant to discharge Service Tax on the Service Contract is as follows: - (a) Paid Service Tax at full rate without any abatement for material consumed on Erection, Installation & Commissioning activities; (b) Paid Service Tax at the rate of 40% (after taking abatement of 60% for material consumed) for Civil Work under "Works Contract Service" in terms of the Rule 2A(ii) of the Service Tax (Determination of Value) Rules, 2006 except in few cases; (c) Did not pay Service Tax on Transportation/Freight & Insurance as the same is incidental to sale of equipment and also on the ground that transportation services rendered by any person other than GTA and courier agency was exempt from Service Tax. Further Insurance service is not an independent service but incidental to main service of transportation. 2.18. On the Civil Contracts, the appellant-company has dischar....
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....ertaken by the appellant-company appears to be one Turnkey Project classifiable under "Works Contract Service" which has been artificially bifurcated into 'Supply Contract', 'Erection, Installation and Commissioning Service' and 'Commercial or Industrial Construction Service' (Civil Work). The entire project being one Turnkey Project of Works Contract Service, Service Tax on entire contract value is payable under Rule 2A(ii) of the Service Tax (Determination of Value) Rules, 2006. (ii) The responsibility of overall project lies with the appellant as there is a cross-fall breach clause in all contracts. Though the contracts provided separate price schedule for different jobs but it did not have any separate liability clause for each of such job according to the price schedule. Therefore, the activity undertaken by the Appellant is one integrated project. (iii) The entire contract being a bundle of service, it is to be treated as "Single Service" and cannot be disintegrated and classified under several services based on the price schedule of the contract. (iv) According to the Explanation 1(b) of the Rule 2A(ii) of the Valuation Rules, the value of the good....
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....of those equipment. Each of the activity is clearly distinct in its nature and necessarily requires separate expertise and the bifurcation of the work is absolutely based on the terms of the tender document. In the case of any Power Project contract, the equipment required are costly and sophisticated. The Erection, Installation and Commissioning of such equipment and Commercial & Industrial Construction (Civil Work) are both clearly distinct jobs and the expertise required to execute both of these jobs are not of like nature. Transport and Insurance services are also provided by the independent service providers. These jobs also involve specialization in its own field. Thus, there is separate commitment for Supply of Equipment and for providing independent services such as undertaking Erection, Installation and Commissioning; Civil Work and Transportation & Insurance of Equipments. (iii) The appellant further submits that the Contract Price Schedule also mentions price for each of the activities separately. The appellant, as per the contract, raises separate invoices for each such activity indicating the price for the respective activity in terms of the contracted price s....
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....orks Contract. According to the Department, this Works Contract includes the value of equipment and its components, Erection, Installation and Commissioning, Commercial & Industrial Construction (Civil Work) and Transportation and Insurance. Accordingly, the appellant is liable to discharge Service Tax on the entire value of the Works Contract less standard deduction allowed in terms of the Valuation Rules. Therefore, it is clearly evident that the Department wants to tax the appellant by looking into the 'substance of transaction' as perceived by the Department in this case. (x) The appellant submits that it is a settled legal position that legal form of transaction cannot be ignored and the Department cannot look at the 'substance of the transaction' ignoring the legal effect of the transaction. In the instant case, the Appellant has undertaken supply of equipment's under a distinctly separate supply contract. The appellant therefore submits that, the legal effect created by virtue of the separate supply and service contracts in the name of the Appellant cannot be overlooked or ignored and brushed aside at the will of the Department to levy service tax on the independent....
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....ixed time schedule. (xv) The cross-fall breach clause between the two contracts can only have the effect that any breach of the conditions in one contract will amount to the breach of the conditions in the other contract. (xvi) Any contract may be a compendium of diverse responsibilities both on the part of the contractee and of the contractor. Breach on either side may invite civil liabilities. It is not only the contractor that is liable for stipulated breach, but equally the contractee has to discharge his obligations. Such common clauses for damages do not make two contracts as one contract. (xvii) In any contract there are modes for settling the disputes including process of notices, mutual consultations, arbitration and civil suits for damages. These are to protect the interest of both the sides. Cross-fall breach mechanism in the realm of law of contracts is to ensure fulfilment of contractual obligations on one or more than one party. It has no bearing on tax liabilities of those who are obliged to pay due taxes under the authority of law. (xviii) Such a stipulation cannot lead to the negation of the constitutional scheme of distribution ....
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....g and Other Construction Workers' Welfare Cess Act, 1996 (Welfare Cess Act), was not collected and deposited by the Respondent vis a vis the First Contract for supply and delivery of equipment and materials. However, the Hon'ble Supreme Court held that there are four separate contracts executed between the parties, and that the 'cess' was only payable in respect of the Third Contract, which covered civil works and not the First and the Second Contracts, which cover all works other than civil works. The Hon'ble Supreme Court also agreed with the arguments put forward by the Respondent that : " the four contracts had been treated as singular contract solely for the purposes of responsibility for timely execution. For all other intents and purposes, including levy of tax or fees, the contract for supply was understood by the parties as a separate and distinct contract." [Para 55] The above decision of the Supreme Court also implies that the Apex Court has in fact, upheld such splitting of turnkey contracts into multiple interconnected contracts in a large construction project, exactly similar to the present case, and also treating the same as separate contracts for t....
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....spect of the goods sold as chattel, appropriate VAT/CST is payable. There is no question of payment of any service tax on the sale of goods as chattel. The question of same contract or separate contract will arise only when they relate to the Works Contract. Separate independent contract for supply of goods cannot be inserted into another completely separate contract for providing services. (xxix) Moreover, in the present case, the relevance of transfer of property in goods arises only with regard to the materials, such as, cement, steel, brick, sand, aggregate, etc. used in execution of service of Civil Construction Work and not in regard to pure supply of equipments. (xxx) The contracts for Erection, Installation and Commissioning Service and for Commercial & Industrial Construction (Civil Work) are said to be Works Contract. Therefore, the valuation for the purpose of determination of taxable value of the service involved shall be only in relation to Erection, Installation and Commissioning Service and for Commercial & Industrial Construction (Civil Work) services. Whereas, in the impugned order, the Ld. Adjudicating authority has sought to enhance the two cont....
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....hat in the instant case, the Department has entirely failed to appreciate the above two separate tests laid down by the Hon'ble Apex Court. The appellant submits that, in line with the position laid down by the Hon'ble Supreme Court, it ought to have first been ascertained whether, on a consideration of the contracts and the concomitant aspects of the transactions, the intention of the parties was to treat the supply of Equipment as a sale activity or as part of provision of Works Contract Service. (xxxvi) In view of the facts mentioned above based on the executed contracts with the customers, the appellant submits that it proves beyond doubt that the appellant always has the intention to treat the supply of equipments as a separate contract for supply only. Therefore, in any case, the value of equipment sold under a distinct supply contract cannot be included in the value of Works Contract for levy of Service Tax. 8.1. Without prejudice to the above, the Ld. Counsel for the appellant has tendered the following submissions on the ground of limitation: - (i) The appellant states that the impugned Show Cause Notice was issued on 11.08.2017 covering the period fro....
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.... submits that the Department at the time of issue of the impugned Show Cause Notice, could not bring on table any cogent evidence to prove that there was existence of at least one of the required situations to enable the Department to invoke the longer period. Whereas, it is an incontrovertible fact on record that the appellant all along considered Supply Contract as pure Supply of goods and accordingly discharged applicable VAT/CST in the respective States. Service Contracts were treated as independent Service Contracts and the appellant discharged Service Tax at the applicable rate where applicable. The appellant submits that it was under bona fide belief that the Contract for Supply of Equipment is pure sale of goods and therefore, this transaction is outside the purview of Service Tax. (vii) The present issue is a pure case of interpretation of law as is evident from the submission made hereinabove. It is the interpretation of the appellant based on the reasonable understanding of law that the value of the pure sale transaction shall not be included in the taxable value of service, whereas the view of the Department is otherwise. If such view of the of the Department i....
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....submits that extended period of limitation cannot be invoked in the present case and hence the part of the demand from 01.04.2012 to 30.09.2014 proposed in the present Show Cause Notice is barred by normal period of limitation as provided in Section 73(1) of the Finance Act, 1994. To this extent Show Cause Notice is liable to be dropped on this ground alone. (xi) It is further submitted that the burden of proof for establishing the ground for invocation of extended period of limitation is on the Department. The impugned order has not bring out the reasons for invoking extended period of limitation. In this regard reliance is placed on the following decisions : (a) Cosmic Dye Chemicals Vs. Commissioner [1995 (75) ELT 721 (SC)] (b) Commissioner Vs. HMM Limited [1995 (76) ELT 497 (SC)] (c) Kaur & Singh Vs. Commissioner [19978 (94) ELT 289 (SC)] (xii) The appellant states that a separate Show Cause Notice bearing F. No. DGGI/GZU/Gr.-F/Inv/552/19-20/2538 to 2543 dated 16.09.2020 was issued on the appellant covering the period from 01.10.2014 to 30.06.2017 by the DGGI, Gurugram Zonal Unit. In the said Show Cause Notice the Department has propo....
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....ated with the Department in their proceedings and always provided the details asked by them. Furthermore, the entire demand was computed based on the data provided by the appellant from its annual audited accounts. The Department could not add any figure neither unearth any figure which could be treated as suppression. Thus there was no suppression at all in the hands of the appellants. Therefore, no penalty is imposable under Section 78 on the appellant-company. (iii) Reliance is placed on the decision of the Tribunal in the case of Eversmile Pre-Fab Private Limited v. Commissioner [2010 (262) ELT 801] wherein the Tribunal held that as the grounds for invocation of extended period of limitation and those for imposition of penalty are same, no penalty can be imposed as the grounds for invoking extended period of limitation do not exist. (iv) The appellant submits that from the submission made hereinabove, it is undoubtedly clear that none of the contraventions specified under Section 77(1) of the Finance Act, 1994 was carried out by the appellant for imposing penalty under Section 77. Therefore, imposition of penalty of Rs.10,000/- by the Ld. Adjudicating Authorit....
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.... paragraph 9.1 confirmed separate service tax demands against each of the 45 registered assessees having separate STC No as detailed in column (7) of paragraph 8.18 of the impugned order. Shri P.P. Gupta was penalised Rs 1,00,000 under Section 78A of the Finance Act, 1994. Unit having STC No AAJCS4414QSD086 was imposed a penalty of Rs 10,000/ under Section 77 of the Finance Act, 1994 for non-filing of ST-3 returns. (vi) The corporate office has filed the present appeal before the CESTAT, Kolkata, against the said impugned order dated 30.10.2024. The 45 other registered units have not filed any separate appeals. (vii) The issue, therefore, is whether a single appeal filed by the corporate office is maintainable before the CESTAT in respect of the impugned order dated 30.10.2024 confirming separate tax demands against multiple service tax registrants, or whether each registered unit was required to file separate individual appeals. (viii) The respondent submits the following statutory provision to argue that the single appeal filed by the Corporate Office is not maintainable. Relevant Statutory Provisions Section 86(1), Finance Act, 1994: ....
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....erely due to the cross -fall breach clause, (b) That valuation under Rule 2A(ii) of the Service Tax (Determination of Value) Rules, 2006 is incorrect, (c) That the extended period of limitation under Section 73(1) proviso was wrongly invoked, and (d) That penalty under Sections 77 and 78 is not sustainable as the issue involves interpretation of law. Ground: Misclassification of Contracts Works Contract" "Composite Turnkey (iv) The OIO correctly held that the contracts for supply and service were inseparable parts of a single turnkey EPC project, executed with cross-fall breach obligations. Para 8.3.5 and 8.11 of the OIO clearly record that failure in one contract automatically renders the other void, thereby evidencing mutual interdependence and commercial indivisibility. (v) The definition of "works contract" under Section 65B(54) of the Finance Act, 1994 expressly includes "turnkey projects including engineering, procurement and construction or commissioning projects". Hence, such EPC projects fall squarely within the statutory definition. (vi) The Hon'ble Supreme Court in Larsen & Toubro Ltd. (supra) held that where a contract involves bo....
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....le filing ST-3 returns, and did not classify the turnkey projects under "Works Contract Service. "The omission of material facts, despite awareness of their tax implications, constitutes suppression of facts with the intent to evade payment, thereby justifying the invocation of the extended period under the proviso to Section 73(1). (xiv) Judicial precedents such as Nizam Sugar Factory v. CCE, A.P. [2006 (197) E.L.T. 465 (S.C.)] and Continental Foundation Jt. Venture v. CCE [2007 (216) E.L.Τ. 177 (S.C.)] have upheld extended limitation in similar cases of mis declaration and non-disclosure. Penalty under Sections 77 and 78 (xv) Penalty under Section 77 was imposed for failure to file returns. Penalty under Section 78 was rightly imposed since there was an apparent misstatement and suppression of the taxable value by splitting supply and service invoices. The plea of "interpretation of law" is untenable because the appellant's conduct shows conscious exclusion of supply value despite having prior departmental audits and multiple registrations. 9.1. In view of these submissions, the Ld. Special Counsel for the Revenue prays for dismissal of the i....
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....bearing No. ST/75328/2025 has been filed by the Corporate Headquarters of the Appellant M/s. Techno Electric and Engg. Co. Ltd., wherein the Accounts of all the 45 Units are maintained. The Accounts are consolidated and a single Balance Sheet is prepared at the end of the Financial Year. Irrespective of the fact that the demand is confirmed against various units of the same company, the final liability to pay the confirmed demand, if any, would lie with the Headquarters. So far as Explanation (2) to Rule 6A is concerned, we do agree that each one person is required to file the Appeal, but this is required wherein the persons are different entities by name as individuals or firms, etc., who are other than the main Noticee. In the present case, the appellant-company is operating under one single PAN Number. Therefore, we do not see as to why the appellant-company herein should be made to file 45 separate appeals when the issue is common and the Head quarters is responsible for the outcome. 11.4. Therefore, we do not find merit in the submissions of the Ld. Special Counsel for the Revenue and take the view that the Appeal filed by the Corporate Office is sufficient for them to cont....
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....een artificially separated for tax purposes. We find that the EPC/Turnkey contracts are divisible contracts for conceptualizing the project, supply of equipment, machinery, infrastructure, services of different nature/categories and a number of other activities which may or may not involve tax liabilities. In this regard, it is relevant to note that when transfer of property in goods is involved in the execution of the contract and such transfer of property in such goods is leviable to tax as sale of goods, such projects and contracts become taxable to Service Tax as a Works Contract. Thus, we observe that the Works Contract is only a part of EPC contracts and it is fallacious to conclude that all EPC contracts are one single Works Contract. 12.3. With regard to the contract for sale of equipment, we observe that the same is a separate contract wherein CST/VAT has been paid on the sale of goods. For ease of reference, sample copy of few of the invoices pertaining to sale of equipments/materials is extracted below: - Invoice No. NTPC/KUDGI/HSS/01 dated 29.06.2015: Invoice No. HINV/14-15/JUN/0034 dated 27.06.2014: 12.3.1. In the present case, the appellant has sold the goods....
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....for Civil Work under "Works Contract Service" in terms of the Rule 2A(ii) of the Service Tax (Determination of Value) Rules, 2006 except in few cases; (c) Did not pay Service Tax on Transportation/Freight & Insurance as the same is incidental to sale of equipment and also on the ground that transportation services rendered by any person other than GTA and courier agency was exempt from Service Tax. Further Insurance service is not an independent service but incidental to main service of transportation. 13.1.1. For the sake of ready reference, relevant pages of the sample ST-3 Return filed, as submitted by the appellant, showing the Service Tax payments made in respect of 'Erection, commissioning and installation Service' and 'Works contract service' (by claiming abatement), are reproduced below: - 13.2. We find that the above practice adopted by the appellant is legally correct. The contracts for Erection, Installation and Commissioning Service and for Commercial & Industrial Construction (Civil Work) are Works Contracts. Therefore, the valuation for the purpose of determination of taxable value of the service involved shall be only in relation to Erection, Installat....
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....n the contract for supply of materials, the description of goods, quantity, unit price, including taxes and duties, freight, insurance etc. were clearly set out. Before the execution of the erection portion of the contract, the contractor paid State levies thereon and then the said goods were supplied by the contractor and the title in the goods/materials passed to the contractee. The contractee became the owner of the said goods/materials. Thereafter in turn, the contractee handed over the said goods/materials, back to the contractor as the trustee for erection work. For civil portion of the contract, the material such as cement, steel, etc. was used by the contractor to lay foundation for erecting transmission towers at certain specified distances. As regards erection portion of the contract, it was purely a labour contract. There was a Cross-fall breach clause in the contract providing that the contractor is bound to perform the total contract in its entirety and non-performance of any part or portion of the contract shall be deemed to be a breach of the entire contract. In that case the Revenue contended that the work entrusted to the contractor was a "turnkey project" and ther....
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....d non-performance of any portion of the contract was to be treated as a breach of the entire contract, Intention is very clear. In order to see that the contractor does not wriggle out of the situation and the object of entering into the contract is not frustrated. The KPTCL., was insisting that it is a composite contract to be performed by the assessee in its entirety. Therefore, it is not a case where a contract which is entered into is not divisible as contract for supply of material and contract for labour. Even if it is a composite contract, if it is a divisible contract, then the levy of tax cannot be on the basis of works contract only. In cases of composite contract, which are not divisible, such contract should be treated as works contract and levy should be under Schedule VI of entry 23. In the instant case, as rightly pointed by the Tribunal, there are four contracts in nature. Each one of them is separate. In respect of the contract for sale of material taxes have been paid in accordance with law. No tax is payable in respect of contract for supply of labour. In civil works, it is a works contract and tax is levied under Schedule VI, entry 23. In those circumstances, we....
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....erefore ascribed to each such contract, the sale of goods would be chargeable to VAT/CST and the service portion would attract the levy of Service Tax; (b) In the event that no such intention can be inferred, the true nature of the composite contract would have to be determined as per the dominant nature test. 13.10. We observe that in the instant case, the Department has failed to appreciate the above two separate tests laid down by the Hon'ble Apex Court. In line with the position laid down by the Hon'ble Supreme Court, it ought to have first been ascertained whether, on a consideration of the contracts and the concomitant aspects of the transactions, the intention of the parties was to treat the supply of Equipment as a sale activity or as part of provision of Works Contract Service. On the basis of the Terms of the contract executed by the appellant with the customers, we observe that it proves beyond doubt that the appellant always has the intention to treat the supply of equipment as a separate contract for supply of equipments only. Therefore, we hold that the value of equipments sold under a distinct supply contract cannot be included in the value of Works Contr....
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....ice tax on the service contract taking it as a Works Contract. Revenue raised the same contention that the value of both the contracts needs to be included in the value of service rendered. The Tribunal considering the same set of facts came to the conclusion that since the contracts were executed prior to 7-7-2009, hence the amended provision do not apply. Accordingly it was held that the value of material supplied under both the contracts cannot be included in the value of Works Contract Service. 6.16 In the present case also the similar facts are involved and the contracts were executed prior to 7-7-2009. Therefore, even if revenue is of the contention that both the contract i.e. one for supply of goods and other for Works Contract Service are meant for one composite contract by virtue of unamended provision, the value of supply contract cannot be included in Works Contract Service." 13.13. Even though the above decision mainly deals with applicability of the amendment in Works Contract (Composition Scheme for Payment of Service Tax) Rules, 2007 for the period prior to 07.07.2009, we find that the said decision also deals with includability of the value of goods supp....
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...., the co-appellant herein, under Section 78A of the Finance Act, 1994. In view of the findings in the preceding paragraphs of this Order, we do not find any reason to sustain the allegations levelled against him. Hence, we hold that the penalty imposed on him is unjustified and accordingly, the same stands set aside. 17. In view of the above findings, we set aside the impugned order qua the demands confirmed against the appellants herein, along with interest and penalties, and allow the appeals, with consequential relief, if any, as per law. (Order pronounced in the open court on 28.10.2025) ============= Document 1 ANN- 6 ANNEXDRE - 6 Exporter/Shipper : ANNENURE-64 000818MMERCIAL INVOICE (1289 TECHNO ELECTRIC & ENGG. CO. LTD. P-46A, Radha Bazar Lane Invoice No. (1289 NTPC/KUDGI/HSS/01 Date : 29.06.2015 Engineers & Contractors (1289 NTPC/KUDGI/HSS/01 Kolkata - 700 001 NTPC LIMITED Kadci Super Thermal Power Project CST No. 19470187261 Near Telgi Pump House, P.D. Kudgi, Taluk - Basavana Bagewadi VAT No. 19470187067 Dist. Bijapur ( Katnataka ) Comoginne : Contract Name : Contract Agreement [ First Contract fo....
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.... 000819 1292 ORIGINAL FOR BUYER TECHNO ELECTRIC & ENGINEERING CO. LTD P - 46A, RADHA BAZAR LANE, KOLKATA - 700001 CAN Na : 40:00W/92005PLC199555 NUNCACS44140 Service Tax No. : AAJC54414050080 GST No: 19470187251 VAŤ N ..: 19470187067 Engineers & Contractors TAX INVOICE Ka ags Super Thermal Power Project Nes- Telagi Prep House Kudagl TQ. Baszvan Bapewadi No. : PIN-014-15/JUN/0634 Dale : 27-JUN-14 CALDA Ne Order No. C5-9573-572-2-SC-NO.A-5839 deled 19.03.2013 G/N / UR Ne, & Transportar CradenPacking List No. 121 stee 26-JUN-14 8-4514 dated 26-JUN-14 Juin Transworld 84515 deted 26-JUN-14 Jain Transworld #451& dstad 25-JJH-14 Jain Transworld 54517 dated 25-JUN-14 Jain Transrsi'd EIN MOTOM Descriadico Oty Rata AmourE MAES EQUIJILENTS DICLUSING STRUCTURAL STEEL 221KW class Equipments (Ctrout breakars Disconnectors / Isolators Current Transformers Surge Arresters Bus Past Insulators! 2150964.90 2150000.00 220XV 25004 40KA Clecuil Braskal (3 Ph) Non 220KV 16004 CCKA Circuit Breaker () PP) BASOCá»C ÄỦ Tesal Ling; Total Tax: 9% Success bud computabon of installation, lesting & commissio....
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....paid A10 Assessee is liable to pay Service Tax on this taxable service as A10.1 A Service Provider under Section 68[1] A10.2 A Service Receiver under Section 68(2) A10.3 A Service Provider under partial reverse charge under proviso to Section 68(2) No A10.4 A Service Receiver under partial reverse charge under pro- viso to Section 68(2) No A10.5 If covered by A10.3 above, then the percentage of Service Tax Payable as Provider of Service A10.6 If covered by A10.4 above. then the percentage of Service Ta Payable as Recipient of Service Descrip- Taxable Services Page 1 of 22 A11 EXEMPTIONS N Notification ('Y'I'N'} A11.1 Has the assessee availed benefit of any exemption in the Notification under A11.2 If reply to A11.1 is 'Y', Please furnish Notification No. and SI. No. which such exemption is availed SI. No SI. No Notification Number A12 ABATEMENTS A12.1 Has any abatement from the value of services been claimed ('Y'/'N') N A12.2 If reply to A12.1 is "Y'. Please furnish Notification No. and SL No. in the Notification under which such abatement is availed SI. No Notification Number SI. No A13 PROVISIONAL ASSESSMENT A13.1 Whether pr....
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.... B1.21 Secondary and Higher Education Cess payable 0 0 A9 Taxable Service(s) for which Tax is being paid (2222a) Descrip- Works contract service tion of Taxable Services Services Taxable Service for which Tax is being Works contract service paid A10 Assessee is liable to pay Service Tax on this taxable service as A10.2 A Service Receiver under Yes Yes A10.1 A Service Provider under Section 68(1) 68(2) A10.3 A Service Provider under partial reverse charge under proviso to Section 68(2) No Section A10.4 A Service Receiver under partial reverse charge under pro- Mecharco une viso to Section 68(2) Yes A10.5 If coveredBydesof overed by A10.3 above, then the percentage of Service Tax Payable as Provider of Service @ A10.6 If covered by A10.4 above, then the Porseringas e percentage of Service Ta as Recipient of Service Payable A11 EXEMPTIONS Y Services Taxable Service for which Tax is being Works contract service paid Assessee is liable to pay Service Tax on this taxable service as A10.2 A Service Receiver under Yes Section A10.4 A Service Receiver under partial reverse charge under pro- Mecharco une viso to Section 68(2) A10....