2026 (6) TMI 1010

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....e (Appeals-II), Bangalore. 2. Briefly the facts are that the appellant is engaged in providing taxi/transit facilities through a controlled room and this service was held to be liable to service tax and accordingly, the Revenue issued notice to the appellant stating that the services were classifiable under the category of Support Services of Business or Commerce. Accordingly, the original authority held that the appellant was liable to pay service tax under the category of Support Services of Business or Commerce and confirmed the demand under the provisions of Section 73(1) of the Finance Act, 1994 along with interest and imposed penalty under Section 78 of the Finance Act. On appeal, the Commissioner (Appeals) upheld the order of the ....

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.... are individuals and relying on the TRU letter F. No.334/4/2006-TRU dated 28.02.2006, it is asserted that only services provided to business entities are liable to service tax. Also, relying on the Circular No.137/6/2011-ST dated 20.04.2011 claims that their services do not fall under the category of support services. Also relying on the decision in the case of Sir Ganga Ram Hospital Vs. CST: 2020 (43) GSTL 390 (Tri.-Del), it is submitted that contractual agreements on agreed revenue sharing does not come within the purview of business support services. It is further submitted that the services rendered by the appellant at best could be the services offered by an 'Aggregator' which was brought into effect only from 01.03.2016. Hence, prior ....

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....ong with office utilities, lounge, reception with competent personnel to handle messages, secretarial services, internet and telecom facilities, pantry and security. 7. The Commissioner (Appeals) in the impugned order has held that the services offered by the appellants are predominantly in the nature of infrastructural support services as they are providing office along with competent personnel to handle 24/7 call centre facilities and accordingly, confirms the demand under the above category. We find that the appellant is into providing taxi services to the customers as and when they approach them telephonically and this service is provided by them by connecting the taxi driver to the customer and to ensure that the customer has a good....