Indirect Taxes

Questions & Answers

Vikram Nankani
Advocate

Nut Crackers

Questions on Service Tax

Q.1. What is the definition of service tax? How it is to be differentiated from other transactions, such as sale of goods or a composite transaction of sale of goods and services?

Ans.: Service tax is defined under section 65(95) of the Finance Act, 1994 (“the Act”) to mean the tax leviable under the provisions of Chapter V of the Act. Service tax is therefore a tax levied on the amount received in respect of the taxable services specified under the Act. Service tax is different from other transactions such as sale of goods or a composite transaction of sale of goods and provision of services. Sale of goods implies the transfer of property in movable goods from one person to another for a valuable consideration. A composite transaction of sale of goods as well provision of services entails both the elements viz., sale as well as services and the transaction in such cases cannot be completed in the absence of either of the elements e.g. Construction Services. As opposed to the above two transactions, Service tax is liable on the rendition of services. The moment a taxable service is rendered it would be liable to Service tax e.g. Banking and other Financial services, Insurance services, Chartered Accountants’ services, Management Consultants’ Services etc. Sale and service are mutually exclusive; i.e., a transaction can either be a sale and accordingly liable to VAT/Sales tax or it can be a service and accordingly liable to Service tax (see BSNL vs. Union of India [2006 (2) STR 161 (SC)]).

Q.2. If a sale is different from transaction for rendering of service, can sale of space for advertisement be subject to service tax under section 65(105)(zzzm)?

Ans.: In order for a transaction of sale to be liable to VAT/Sales tax, there must be a sale of ‘goods’. In other words there must be transfer property in movable goods from one person to another for valuable consideration.

Under the taxing entry of Sale of Space or Time for Advertisement Service, there is no transfer of property in ‘goods’ inasmuch as the space or time for advertisement does not constitute ‘goods’ as defined under the Act/Sale of Goods Act, 1930. Since the transaction does not involve sale of ‘goods’ it would not be liable to VAT/Sales tax.

Under the Act, the taxable service has been defined to mean any service in relation to sale of space or time for advertisement in any manner. Therefore, the liability to Service tax is not on the transaction of sale of space or time but on services in relation to such sale such as the commission of the intermediary or agent involved in relation to such sale.

Q.3. Can it be said that services are rendered and consumed simultaneously and, therefore, services cannot be stored? If the answer is ‘yes’, can services ever be imported from outside India? If the answer is ‘no’, can it be said that there is difference between goods and services?

Ans.: Service tax is a tax on rendition of service. Whether the taxable event is distinct or whether it coincides with consumption is irrelevant to the levy of the tax. In a given case, service may be consumed at the same time / simultaneously with the rendition and in another case, there may be a difference in the time and place between rendition and consumption of the service.

Q.4. If a person has entered into a non-cancellable lease of an immovable property for a period of 10 years, it is a transaction in capital asset subject to capital gains tax under Income Tax Law. Can such transaction be regarded as a sale transaction (transfer of a right) and, therefore, not taxable under the category of “renting of immovable property”?

Ans.: Liability to capital gains tax under the Income-Tax Act, 1961 is independent of levy of Service tax as they are governed by two different statutes. The scheme and purpose of both the said statutes are different. The Income-tax Act seeks to tax the income earned by an assessee in a transaction whereas Service tax is a tax on the levy of taxable services. Income tax is a direct tax and is liable in the hands of the assessee, whereas Service tax is an Indirect tax, the liability accruing on the rendition of taxable service. The transaction of renting/leasing of immovable property is governed by
section 105 of the Transfer of Properties Act, 1882 and is therefore, not a sale and is distinct from a sale.

Q.5. Is advance received for rendering service taxable, when there-no taxable event at that point of time?

Ans.: The taxable event is the rendition of taxable service or receipt of money whichever is earlier. If an advance is received for rendition of taxable service then such advance would be liable to Service tax.

This is because section 65(105) of the Act was specifically amended by Finance Act, 2005 to cover not only services rendered but also to be rendered. However, Rule 6(3) provides that if the services not rendered for any reason whatsoever, such as, cancellation of contract, the Service tax paid on the basis of the amount received in advance shall be adjusted against liability in respect of other taxable services. The Rule is silent on the situation of no service being provided at all. In such a situation the refunded of service tax paid is implied.