TaxTMI 
TaxTMI 
2026 (9) TMI 548
X X X X Extracts X X X X
X X X X Extracts X X X X
....noticed that the appellant was in the business of translation of one language into another and this service was considered to be Business Support Services and accordingly, notice was issued demanding service tax. The Commissioner in the impugned order referring to the copy of the agreement entered into between M/s. Infosys Technologies Ltd. and the appellant observed that the scope of work included translation of business requirement documents, design documents, help documents etc; also from the financial statements and correspondences, held that these services were rightly classifiable under the category of Business Support Services, accordingly confirmed the demand of service tax of Rs.58,86,138/- along with interest and penalty. Aggrieve....
X X X X Extracts X X X X
X X X X Extracts X X X X
....f the Commissioner in the impugned order. 4. Heard both sides. There is no dispute that the appellant is engaged in the business of translation of one language into another language for organisations like M/s. Manipal Acunova Ltd. and M/s. Infosys Technologies Ltd. where they are engaged to translate various documents from one language to another either from English to regional languages or from English to various other foreign languages or vice versa. It would be relevant to peruse the definition of Business Support Service, which is reproduced below: Section 65(104c) of the Finance Act, 1994 defines Business Support Services means 'services provided in relation to business or commerce and includes evaluation of prospective cus....
X X X X Extracts X X X X
X X X X Extracts X X X X
....it. It is essentially an across the counter job. A person who wants some document to be translated approaches the appellant and gets the work done by paying the prescribed fee. The appellants are not even aware for what purpose the translated documents may be put to use. Some of the customers happened to be organizations or corporate companies by itself does not make the service as a business support service. The statutory definition of Business Support Service (BSS) in terms of Section 65(104c) of the Finance Act, 1994 stipulates that services should be provided in relation to business or commerce and nature of such services are evaluation of customers, telemarketing, processing of purchase orders, information and tracking of delivery sche....