Litigation Track Record

APRA's indirect tax case studies

Practice Area
Forum
45 cases
Service Tax & Excise

Construction services provided to Government sectors not taxable; Contracts with material can be classified under Works Contract services only

That Section 65 (105) (zzzza) which defines 'Works Contract Service' was introduced and came into effect from 01 June 2007 to include the services provided along with material into Service tax net. In other words, the introduction of the 'Works Contract Service' was for the pu…

CESTAT2024Read →
Service Tax & Excise

Logistics support services do not fall under GTA services

'Goods Transport Agency' was taxable under Section 65(105)(zzp) as 'any service provided or to be provided to any person by a goods transport agency, in relation to transport of goods by road in a goods carriage.' Section 65(105)(zzp) read with Section 65(50b) of the Finance Act stated that any pers

CESTAT2023Read →
Service Tax & Excise

Interest to be remitted from the date of deposit at the rate of 12% in case of refund claim filed for the amount deposited during investigation

Section 11B of the Central Excise Act, 1944 (applicable to Service Tax vide Section 83 of the Finance Act) provides for claim of refund of duty. The person claiming the refund under this Section can file an application before the Authorities within one year of the relevant date.

CESTAT2023Read →
Service Tax & Excise

Demand beyond the scope of SCN not sustainable; supply of tangible goods with control and possession would be covered under 'right to use'

In the previous cases, we have already discussed regarding the vagueness of the show cause notice or adjudication order. If the charge is not clear in the show cause notice, disabling the assessee to respond to it, the said show cause notice would not sustain in the eyes of law.

CESTAT2023Read →
Service Tax & Excise

Extended period cannot be invoked where the Department has the knowledge of activities carried on by the assessee and the assessee is duly filing its returns disclosing the whole information

Section 73(1) of the Finance Act defines the situation when extended period would be invokable i.e., in case of 'suppression of fact'; 'fraud'; 'collusion' or 'wilful misstatement.' Section 11A of the Central Excise Act, is para materia to Section 73(1). It is quite clear that…

CESTAT2023Read →
Service Tax & Excise

Confirmation of demand through issuance of vague and incoherent show cause notice not sustainable and liable to be set aside

Show cause notice is the foundation of the case made against the assessee. If the department is of the view that the assessee has not paid tax required to be paid or if there is any contravention of the provisions of the act on the behalf of the assessee, the department can issue a show cause notice

CESTAT2023Read →
Service Tax & Excise

Confirmation of demand under Business Auxiliary Service without mentioning the specific clause under which the services provided by the assessee would be covered, not sustainable

Business Auxiliary Service was defined under Section 65 (105) (zzb) read with Section 65(19) of the Finance Act, which aimed to mainly bring 'Commission Agents' under the ambit of Service Tax. Any person who acts on behalf of another person and causes sale or purchase of goods…

CESTAT2023Read →
Service Tax & Excise

Extended period not invocable if the receipts of the assessee duly recorded in ITR returns – whole demand time barred and the assessee also entitled to SSI exemption

The Principles of Natural justice has to be followed while adjudicating the matter and also while considering the appeal filed against the adjudication order. Providing an opportunity to the assessee to file a reply to the show cause notice or to present its case and opportunity of hearing are the k

CESTAT2023Read →
Service Tax & Excise

Extended period not invocable when there is no intent to evade payment of tax on behalf of the assessee

It has already been discussed in detail in the previous cases that in what circumstances the extended period can be invoked. Section 73(1) of the Finance Act defines the situation when extended period would be invokable i.e., in case of 'suppression of fact'; 'fraud'; 'collusion' or 'wilful misstate

CESTAT2023Read →
Service Tax & Excise

Premium charged on restructuring of loan – whether taxable under service tax?

Section 67 of the Finance Act prescribes 'Valuation of taxable services for charging service tax'. It explains what to be included in the 'Consideration' and what is to be excluded from the value of taxable services.

CESTAT2022Read →
GST

No tax on notice pay recovery; GST not applicable on subsidised canteen charges recovered from employees; printing ID cards for employees would also not attract GST

After the introduction of the GST laws, a confusion arose in the industry as to whether the damages claimed by the assessee/companies, such as liquidated damages, forfeiture of surety bond, earnest money, security deposit, bank guarantee etc. would attract GST or not. The indu…

AAR2022Read →
Service Tax & Excise

Extended period not invokable where the assessee is under a bona fide belief that the services provided by them are not taxable

Section 73(1) of the Finance Act defines the situation when extended period would be invokable i.e., in case of 'suppression of fact'; 'fraud'; 'collusion' or 'wilful misstatement.' Section 11A of the Central Excise Act, is para materia to Section 73(1). It is quite clear that extended period of lim

CESTAT2020Read →
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