(i) Recent Notifications on Service Tax with analysis Reporter

 

            REPORTED BY POONAM JOSHI

Tax Consultant

 

Note: Comments are given at the end of each notification by reporter.

 

Notification No. 21/2005‑Service Tax, Dated : June 7. 2005

 

G.S.R. (E).‑ In exercise of the powers conferred by sub‑section (1) of section 93 of the Finance Act, 1994 (32 of 1994) (hereinafter referred to as the Finance Act), the Central Government, on being satisfied that it is necessary in the public interest so to do, hereby exempts the taxable service of production or processing of goods for, or on behalf of, the client, referred to in sub‑clause (v) of clause (19) of section 65 of the said Finance Act, provided by a commercial concern, in the course of manufacture of,

(a)        cut and polished diamonds and gem stones; or

(b)        plain and studded jewellery of gold and other precious metals, falling under Chapter 71 of the Central Excise Tariff Act, 1985 (5 of 1986), from the whole of service tax leviable thereon under section 66 of the said Finance Act.

 

2.         This notification shall come into force on the 16th day of June, 2005.

 

[F. No. B11512005‑TRU]

 

Comments: Vide this notification the services provided by the job workers as regard job work of cut and polished diamonds and gems and as regard plain and studded jewellery of gold and other precious metals, which are falling under Chapter 71 of the Central Excise Tariff Act, 1985 has been exempted from service tax.

 

Notification No. 22/2005‑Service Tax, Dated : June 7, 2005

 

G.S.R. (E).‑ In exercise of the powers conferred by sub‑section (1) of section. 93 of the Finance Act, 1994 (32 of 1994) (hereinafter referred to as the Finance Act), the Central Government, on being satisfied that it is necessary in the public interest so to do, hereby exempts the taxable services specified in sub‑clauses (h), (i), 0), (zn), (zr), (zza), (zzg), (zzi) and (zzl) of clause (105) of section 65 of the Finance Act provided by a non‑resident person outside India and consumed outside India, in the course of sailing of a ship which is,

 

(a)        registered as an Indian ship under the Merchant Shipping Act, 1958 (44 of 1958);

(b)        registered under the Coasting Vessels Act, 1838 (19 of 1838);

(c)        registered under the Inland Vessels Act, 1917 (1 of 1917); or

(d)        chartered and licensed under the Merchant Shipping Act, 1958, and such ship is owned or chartered, as the case may be, by,­-

(i)         a citizen of India;

                        a company or a body established by or under any Central Act or State Act

            which has its principal place of business in India; or

 

(iii)       a ‑co‑operative society which is registered or deemed to be registered under the Co‑operative Societies Act, 1912 (2 of 1912), or any other law relating to co‑operative societies for the time being in force in any State, from the whole of service tax leviable thereon under section 66 of the said Finance Act:

 

Provided that the said exemption shall apply only in such cases where the said taxable services are provided in relation to,-

(a)        handling of ships in a port outside India;

(b)        handling or storage of goods carried in a ship in a port outside India; or

(c)        any other services related to the handling of ships or goods carried in a ship.

 

Explanation.- For the purposes of this notification, "non‑resident person" means a person, who has established a business or has a fixed establishment from which the service is provided or to be provided, or has his permanent address or usual place of residence, in a country other than India.

 

2.         This notification shall come into force on the 16th day of June, 2005.

 

[E No. B11712005‑TRU]

 

Comments: The specified services as mentioned above in proviso to this notification, if provided to shipping companies by non‑resident outside India and consumed outside India in the course of sailing of ship is exempt from service tax.

 

Notification No. 23/2005‑Service Tax, Dated June 7. 2005

 

G.S.R. (E), In exercise of the powers conferred by sub‑sections (1) and (2) of section 94 of the Finance Act, 1994 (32 of 1994), the Central Government hereby makes the following rules further to amend the Service Tax Rules, 1994, namely :

 

1          (1) These rules may be called the Service Tax (Fifth Amendment) Rules, 2005.

            (2) They shall come into force on the 16th day of June, 2005.

2.         In the Service Tax Rules, 1994, (hereinafter referred to as the said rules), in rule 2,

in sub‑rule (1), in clause (d),-

(i) for sub‑clause (iv), the following sub‑clause shall be substituted, namely:

"(iv)      in relation to any taxable service provided or to be provided by a person, who has established a business or has a fixed establishment from which the service is provided or to be provided, or has his permanent address or usual place of residence, in a country other than India, and such service provider does not have any office in India, the person who receives such service and has his place of business, fixed establishment, permanent address or, as the case may be, usual place of residence, in India;";

(ii) in sub‑clause (v), in item (b), for the words "established by or under", the words I "formed or   

     registered under" shall be substituted.

 

3.         In the said rules, in rule 4A, in sub‑rule (1), after the second proviso, the following proviso shall be inserted, namely:-

"Provided also that where any payment towards the value of taxable service is not received and such taxable service is provided continuously for successive periods of time and the value of such taxable service is determined or payable periodically, an invoice, a bill, or as the case may be, a challan shall be issued by a person providing such taxable service, not later than fourteen days from the last day of the said period.".

 

4.         In the said rules, in rule 6, after sub‑rule (4), the following sub‑rule shall be inserted, namely:-

"(4A) Notwithstanding anything contained in sub‑rule (4), where an assessee has opted for registration under sub‑rule (2) of rule 4 of these. rules and has paid to the credit of Central Government any amount in excess of the amount required to be paid towards service tax liability for a month or quarter, as the case may be, for the reason of not receiving details of payments received towards the value of taxable services at his other premises or offices, the assessee may adjust such excess amount so paid as service tax by him against his service tax liability for the subsequent period and the details of such adjustment shall be intimated to the jurisdictional Superintendent of Central Excise within a period of fifteen days from the date of such adjustment.".

 

[F No. B‑11612005‑TRU]

Note.- The principal rules were notified vide notification No. 2/94‑Service Tax, dated the 28th June 1994 and published in the Gazette of India, Extraordinary vide number G.S.R.546 (E), dated the 28th June 1994 and were last amended vide notification No. 7/ 2005‑Service Tax, dated the 1st March, 2005 which was published vide number G.S.R. 141 (E), dated the 1st March, 2005.

 

Comments: Point wise amendments and insertions made under Service Tax Rules 2002

·         Date of enforcement of the amendments made in Service Tax Rules 2002:-

The amendments made in Service Tax Rules 2002 vide this notification shall be enforced and come into effect from 16.6.2005

·         Prior to 16.6.2005 following sub clauses of Rule 2 of Service Tax Rules, 2002 read as under:

" iv) in relation to any taxable service provided by a person who is a non‑resident

or is from outside India, does not have any office in India, the person receiving

taxable service in India."

 

"(v)(b), any company established by or under the Companies Act, 1956 (1 of 1956);"

 

·         Invoice when service is provided on continuous basis:

As per proviso introduced w.e.f 16.6.2005 in rule 4A, in sub‑rule (1), of Service Tax Rules,2002 the cases in which service is provided continuously for successive periods of time and value of such taxable service is determined or payable periodically, in such cases, the invoice or challan shall be issued within 14 days from last date of the period.

 

·         Person having centralized registration can himself adjust excess payment made:

As it is difficult for a person to get details from various branches in time as the service tax is to be paid on 5th of the subsequent month or quarter as the case may be. In this regard a sub rule 4A to Rule 6 has been inserted, which provides a person with a facility to pay the service tax on higher side and to adjust the excess tax paid against tax liability of subsequent period.

 

Notification No. 24/2005‑Service Tm, Dated June 7, 2005

 

G.S.R. (E).‑ In exercise of the powers conferred by sub‑section (2) of section 68 bf the Finance Act, 1994 (32 of 1994), the Central Government, on being satisfied that it is necessary in the public interest so to do, hereby makes the following further amendments in notification of the Government of India in the Ministry of Finance (Department of Revenue) No. 36/2004‑Service Tax, dated the 31st December, 2004 which was published in the Gazette of India, Extraordinary, vide number G.S.R. 849 (E), dated the 31st December, 2004, namely:

 

In the said notification,

 

(i)         in paragraph (A), in sub‑paragraph (iv), in item (b), for the words "established by or under", the words "formed or registered under" shall be substituted‑,

(ii)        for paragraph (B), the following paragraph shall be substituted, namely:­

"any taxable service provided or to be provided by a person, who has established a business or has a fixed establishment from which the service is provided or to be provided, or has his permanent address or usual place of residence, in a country other than India, and such service provider does not have any office in India.".

 

2.         This notification shall come into force on the 16th day of June, 2005.

 

[F. No. B11612005‑TRU]

 

Note,- The principal notification No. 36/2004‑Service Tax, dated the 31st December, 2004 was published in the Gazette of India, Extraordinary, dated the 31st December, 2004 vide number G.S.R. 849 (E), dated the 31st December, 2004 and was last amended vide notification No. 5/2005‑Service Tax, dated the 1st March, 2005 [G.S.R. 139 (E) dated the 1st March, 2005];

 

 

Comments:- This notification has made the following highlighted changes in Notification No. 36 /2004‑Service Tax, Dated: December 31, 2004

 

In exercise of the powers conferred by sub‑section (2) of section 68 of the Finance Act, 1994 (32 of 1994), the Central Government hereby notifies the following taxable services for the purposes of the said sub‑section, namely:

 

(A)       the services,­-

(i)         in relation to a telephone connection or pager or a communication through telegraph or telex or a facsimile communication or a leased circuit;

(ii)        in relation to general insurance business;

(iii)       in. relation to insurance auxiliary service by an insurance agent; and

(iv)       in relation to transport of goods by road in a goods carriage, where the consignor or consignee of goods is,

(a)        any factory registered under or governed by the Factories Act, 1948 (63 of 1948);

(b)        any company formed or registered under the Companies Act, 1956 (1 of 1956);

(c)        any corporation established by or under any law;

(d)        any society registered under the Societies Registration Act, 1860 (21 of 1860) or under any law corresponding to that Act in force in any part of India;

(e)        any co‑operative society established by or under any law;

(f)         any dealer of excisable goods, who is registered under the Central Excise Act, 1944 (1 of 1944) or the rules made thereunder; or

(g)        any body corporate established, or a partnership firm registered, by or under any law;

(v)        in relation to business auxiliary service of distribution of mutual fund by a mutual fund distributor or an agent, as the case may be; (point no. (v) has been added vide notification no. 5/2005 dated 1‑3‑2005 and this change will be effective from 1st day of April, 2005).

 

(B)       any taxable service provided or to be provided by a person, who has established a business or has a fixed establishment from which the service is provided or to be provided, or has his permanent address or usual place of residence, in a country other than India, and such service provider does not have any office in India. (This paragraph has been substituted vide Notification No. 24/2005, Dt 7‑6‑05)

 

2.         This notification shall come into force on the first day of January, 2005.

 

[F No. 34111812004‑TRU (Pt.)]

 

In paragraph (A), in sub‑paragraph (iv), in item (b), for the words "established by or under", the words "formed or registered under" shall be substituted vide Notification No. 24/2005, Dt 7‑6‑05

 

 

Notification No. 25/2005‑Service Tax, Dated : June 7, 2005

 

G.S.R. (E).‑ In exercise of the powers conferred by sub‑section (1) of section 93 of the Finance Act, 1994 (32 of 1994) (hereinafter referred to as the Finance Act), the Central Government, on being satisfied that it is necessary in the public interest so to do, hereby exempts any taxable service provided to an individual by a service provider, where the said taxable services are received and consumed outside India, by such individual, not in the course or furtherance of commerce or industry or any other business, from the whole of service tax leviable thereon under section 66 of the Finance Act.

 

2.         This notification shall come into force on the 16th day of June, 2005.

 

[E No. B11612005‑TRU]

Comments:- An individual if utilizes some taxable services abroad which are not in the course or furtherance of business rather for personal use, the service so consumed have been made exempted by this notification.

 

Notification No. 26/2005‑Service Tax, Dated June 7, 2005

 

G.S.R. (E).‑ In exercise of the powers conferred by sub‑section (2) of section 69 of the Finance Act, 1994 (32 of 1994), the Central Government hereby specifies the following person or class of persons who shall make an application for registration under the provisions of the said sub‑section, namely:-

(i)         an input service distributor; and

(ii)        any provider of taxable service whose aggregate value of taxable service in a financial year exceeds three lakh rupees.

 

Explanation 1.‑ For the purposes of this clause, where a provider of taxable service provides one or more taxable services from one or more premises, the aggregate value of all such taxable services and from all such premises and not separately for each services or each premises shall be taken into account for computation of aggregate value of taxable service.

 

Explanation 2,- For the purposes of this notification,

(a)        "input service distributor" has the meaning assigned to it in clause (m) of rule 2 of the CENVAT Credit Rules, 2004;

(b)        "aggregate value of taxable service" means the sum total of first consecutive payments received during a financial year towards the gross amount, as prescribed under section 67 of the said Finance Act, charged by the service provider towards taxable services but does not include payments received towards such gross amount which are exempt from the whole of service tax leviable thereon under section 66 of the said Finance Act under any notification other than Notification No. 6/2005‑Service Tax, dated the 1st March, 2005 [G.S.R. 140 (E), dated the 1st March, 2005].

 

2.         This notification shall come ; ) force on the 16th day of June, 2005.

 

 

Comments: Prior to 16.6.2005, there was no provision for registration of Input Service. Distributor. This notification provided that existing Input Service Distributor should shall make an application for registration with service tax cell within thirty days i.e., till 16.7.2005. However, in case of new Input Service Distributor, he should get registered within 30 days from the commencement of business.

 

Notification No. 27/2005‑Service Tax, Dated June 7. 2005

 

G.S.R. (E).‑ In exercise of the powers conferred by sub‑sections (1) and (2) of section 94 of the Finance Act, 1994 (32 of 1994), the Central Government hereby makes the following rules, namely:

 

1.                  Short title and commencement.-

(1)        These rules may be called the Service Tax (Registration of Special Category of Persons) Rules, 2005.

(2)        They shall come into force on the 16th day of June, 2005.

2.                  Definitions.‑ In these rules, unless the context otherwise requires,-

(a)        "Act" means the Finance Act, 1994 (32 of 1994);

(b)        "aggregate value of taxable service" means the sum total of first consecutive payments received during a financial year towards the gross amount, as prescribed under section 67 of the Act, charged by the service provider towards taxable services but does not include payments received towards such gross amount which are exempt from the whole of service tax leviable thereon under. section 66 of the Act under any notification other than Notification No. 6/2005Service Tax, dated the 1st March, 2005 [G.S.R. 140 (E), dated the 1st March, 2005];

(c)        "input service distributor" shall have the meaning assigned to it in clause (m) of rule 2 of the CENVAT Credit Rules, 2004.

3.                  Registration.-

(1)        The input service distributor shall make an application to the jurisdictional Superintendent of Central Excise in such form as may be specified, by notification, by the Board, for registration within a period of thirty days of the commencement of business or the 16th day of June, 2005, whichever is later.

(2)        Any provider of taxable service whose aggregate value of taxable service in a financial year exceeds three lakh rupees shall make an application to the jurisdictional Superintendent of Central Excise in such form as may be specified, by notification, by the Board, for registration within a period of thirty days of exceeding the aggregate value of taxable service of three lakh rupees.

(3)        The provisions of sub‑rules (2) to (7) of rule 4 of Service Tax Rules, 1994 shall be applicable to the persons or class of persons who make an application for registration under the provisions of these rules, with such modifications and alterations as may be prescribed by the Board.

4.         Furnishing of returns.‑ The input service distributor shall furnish a return to the jurisdictional Superintendent of Central Excise in such form and at such frequency as prescribed under sub‑rule (10) of rule 9 of CENVAT Credit Rules, 2004.

 

[F. No. B11612005‑TRU]

Comments:- This notification has introduced new rules for Registration of Special Category of Persons) Rules, 2005, defining the various terms and procedures. Following shall be required to take registration as per these rules:

i)          Input Service Distributors

ii)         Service provider who is exempt but whose aggregate value of taxable service exceeds Rs.3 lakhs.

 

Notification No. 28/2005‑Service Tax, Dated June 7, 2005

 

G.S.R. (E).‑ In exercise of the powers conferred by sub‑sections (1) and (2) of section 94 of the Finance Act, 1994 (32 of 1994), the Central Government hereby makes the following rules to amend the Export of Services Rules, 2005, namely :

 

1.         (1) These rules may be called the Export of Services (Amendment) Rules, 2005.

(2) They shall come into force on the 16th day of June, 2005.

2.         In the Export of Services Rules, 2005, in rule 3,­-

            (i) in sub‑rule (1),­-

(a)   for the word, brackets and letters "and (zzq) ", the brackets, letters and word", (zzq), (zzza), (zzzb), (zzzc) and (zzzh)" shall be substituted;

(b)    the following proviso shall be inserted at the end, namely: ‑"Provided that for the purposes of this sub‑rule, any taxable services provided shall be treated as export of services only if­(a)          such service is delivered outside India and used in business or for any other purpose outside India; and

(b) payment for such service provided is received by the service provider in convertible foreign exchange.";

(ii) in sub‑rule (2),­-

(a)  for the word, brackets and letters "and (zzy)", the brackets, letters and word", (zzy), (zzzd), (zzze) and (zzzf)" shall be substituted;

(b)  after the first proviso, the following proviso shall be inserted, namely:-

“Provided further that for the purposes of this sub‑rule, any taxable services provided shall be treated as export of services only if­

(a) such service is delivered outside India and used in business or for any other 

      purpose outside India; and

(b) payment for such service provided is received by the service provider in

      convertible foreign exchange.";

(iii) in sub‑rule (3),­-

(a) in clause (i), for the word, brackets and letters "and (zzy)", the brackets, letters and word ", (zzy), (zzza), (zzzb), (zzzd), (zzze), (zzzf) and (zzzh)" shall be substituted;

(b) in clause (ii), for the brackets and letter "(d)", the brackets, letters and word "(d) and (zzzc)" shall be substituted.

 

 [F. No. B11612005‑TRUI

 

Comments: Export of Service Rules have been amended w.e.f 16.6.2005 to the effect that, service falling in rule 3(l) and 3(2) of Export of Service Rules, the service will be export of service only if a) the service is delivered outside India and used in the business or for any other purpose outside India and b) Payment is received by service provider in free foreign exchange.

 

 

(II)  New Services under Service Tax w.e.f. 16‑6‑2005

 

As per Ministry of Finance, Department of Revenue, Tax Research Unit notification F.No. 15/2005‑Service Tax dated 7th June, 2005, the following new services have come under the Service Tax levy w.e.f. 16.6.2005.

 

SI. No.

                                            Name of Service

Account Code

 

 

Tax Collection

Other Receipts*

1.

Transport of goods through pipeline or other conduit

00440302

00440303

2.

Site formation and clearance, excavation and earth

00440306

00440307

 

Moving and demolition services, other than those

 

 

 

provided to agriculture, irrigation and watershed

 

 

 

development

 

 

3.

Dredging service of river, port, harbour, backwater

00440310

00440311

 

or estuary.

 

 

4.

Survey and map making other than those by

00440314

00440315'

 

Government departments

 

 

5.

Cleaning other than in relation to agriculture,

00440318

00440319

 

horticulture, husbandry or dairying.

 

 

6.

Membership of club or association with specified

00440322

00440323

 

exclusions.

 

 

7.

Packaging services.

00440326

00440327

8.

Mailing list compilation and mailing

00440330

00440331

9.

Construction of residential complexes having more

00440334

00440335

 

than twelve residential houses or apartments together

 

 

 

with common areas and other appurtenances

 

 

 

",Other Receipts" is meant for interest, penalty leviable on delayed payments.