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1 All India Chartered Accountants Society 4th Workshop on Service Tax (Session XX II) Date: 23 July, 2011 Dr. Sanjiv Agarwal New DelhiFCA, FCS, ACIS(UK)

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Presentation on theme: "1 All India Chartered Accountants Society 4th Workshop on Service Tax (Session XX II) Date: 23 July, 2011 Dr. Sanjiv Agarwal New DelhiFCA, FCS, ACIS(UK)"— Presentation transcript:

1 1 All India Chartered Accountants Society 4th Workshop on Service Tax (Session XX II) Date: 23 July, 2011 Dr. Sanjiv Agarwal New DelhiFCA, FCS, ACIS(UK) Jaipur

2 2 This Session Covers Accommodation Services w.e.f. 1 May 2011 Section 65(105) (zzzzw) Restaurant Services w.e.f. 1 May 2011 Section 65 (105) (zzzzv) Health Care (Medical) Servicesupto 30 April 2011 Section 65 (105) (zzzzo)

3 3 Accommodation Services Introduced by Finance Act, 2011 Introduced by Finance Act, 2011 W.e.f. 1 May, 2011 (Notification No. 29/2011-ST dated ) W.e.f. 1 May, 2011 (Notification No. 29/2011-ST dated ) Section 65(105) (zzzzw) of Finance Act, 1994 Section 65(105) (zzzzw) of Finance Act, 1994 Accommodation- Not defined Accommodation- Not defined To provide lodging or sufficient space To provide lodging or sufficient space Room, group of rooms or buildings in which some one may live or stay Room, group of rooms or buildings in which some one may live or stay Lodgings Lodgings Available space for occupants in a building Available space for occupants in a building Some where to live; some where to stay ; lodging; housing; room; space, place (English Dict. UK) Some where to live; some where to stay ; lodging; housing; room; space, place (English Dict. UK) Dwelling or place of temporary residence (Wikipedia) Dwelling or place of temporary residence (Wikipedia)

4 4 Accommodation Services Includes both residential as well as non residential purposes- Prem Narayan Barchhiha v Hakimuddin Saifi (1999) 6 SCC 381 SC [M P Accommodation Control Act, 1961]. Includes both residential as well as non residential purposes- Prem Narayan Barchhiha v Hakimuddin Saifi (1999) 6 SCC 381 SC [M P Accommodation Control Act, 1961]. Means a building or a part of building which is used for residential or non residential purposes, but not as a factory or for industrial purposes- Sitaram Shashan v Johrimal (1972) 317 AIR Allahabad [U P (Temporary ) Control of Rent and Eviction Act, 1947)] Means a building or a part of building which is used for residential or non residential purposes, but not as a factory or for industrial purposes- Sitaram Shashan v Johrimal (1972) 317 AIR Allahabad [U P (Temporary ) Control of Rent and Eviction Act, 1947)] Garage, a permanent roofed structure and which is part of a building would come within the purview of accommodation. Garage, a permanent roofed structure and which is part of a building would come within the purview of accommodation. R.N.Gupta v Sarla Khandelwal AIR 74 Allahabad 377 [UP (Temporary) Control of Rent and Eviction Act, 1947)] R.N.Gupta v Sarla Khandelwal AIR 74 Allahabad 377 [UP (Temporary) Control of Rent and Eviction Act, 1947)]

5 5 Accommodation Services Service Provider – Receiver Service Receiver-Any person Service Receiver-Any person Service Provider-To be any of the following - Service Provider-To be any of the following -HotelInn Guest house ClubCampsite Others, by whatever name called None of the above defined in statutory provisions None of the above defined in statutory provisions Club or association defined u/s 65(25a)- Any person or body of persons providing services, facilities or advantages primarily to its members, for a subscription or any other amount, but does not include ……. Club or association defined u/s 65(25a)- Any person or body of persons providing services, facilities or advantages primarily to its members, for a subscription or any other amount, but does not include …….

6 6 Accommodation Services Taxable Service [Section 65(105) (zzzzw)] Any service provided or to be provided to any person by a hotel, inn, guest house, club or campsite, by whatever name called, in relation to providing of accommodation for a continuous period of less than three months. Taxability Tests Service provider Service provider Accommodation Accommodation Declared tariff Declared tariff Period Period

7 7 Accommodation Services Basic Ingredients of Taxable Services accommodation services can be provided to any person accommodation services can be provided to any person service should be in relation to accommodation service should be in relation to accommodation service should be provided by / accommodation must be at any of the following – service should be provided by / accommodation must be at any of the following – hotel hotel Inn Inn guest house guest house club, or club, or campsite campsite Such places may also be known by any other name such as resort, motel, service apartments etc. Such places may also be known by any other name such as resort, motel, service apartments etc. accommodation must be provided for a continuous period of less than three months. accommodation must be provided for a continuous period of less than three months. accommodation for a period of three months or more are not covered in the scope of taxable services. accommodation for a period of three months or more are not covered in the scope of taxable services.

8 8 Accommodation Services Coverage Criteria Vide Notification No 31/2011-ST dated , actual levy of service tax shall be restricted to cases where the declared accommodation tariff is of Rs per day per room or higher. Once this criteria is met, service tax would be levied irrespective of trade or tariff discounts given to guests. Taxability not to be affected when actual amount charged from guest/ customer is less than Rs as service tax is levied on actual amount charged. Taxability not to be affected when actual amount charged from guest/ customer is less than Rs as service tax is levied on actual amount charged.

9 9 Accommodation Services Accommodation for continuous period of three months Cases of continuous period of 3 months or more to be excluded from scope of tax Service Tax. Cases of continuous period of 3 months or more to be excluded from scope of tax Service Tax. Continuous stay is crucial Continuous stay is crucial Broken period, even if more than > 3 months to be taxable. Broken period, even if more than > 3 months to be taxable. Holiday home taken by a bank or organizations for >3 months – not taxable. Holiday home taken by a bank or organizations for >3 months – not taxable. Rooms used as office on monthly may rent not covered. Rooms used as office on monthly may rent not covered.

10 10 Accommodation Services What is declared tariff Relevant in determining liability to pay Service Tax. Includes Charges for all amenities provided in unit of accommodation like – furniture air conditioner refrigerator charges for all electronic gadgets installed in room (TRU Letter dated ) any other facility provided by hotel as a part of stay cost of meals included in declared tariff. Does not include Any discount offered on published charges for such unitAny discount offered on published charges for such unit Cost of extra bed (TRU Letter dated ) Declared Tariff v. Published charges

11 11 Accommodation Services Valuation Gross amount billed to guest Gross amount billed to guest Optional abatement vide Notification No. 34/2011 Service Tax Optional abatement vide Notification No. 34/2011 Service Tax dated 50 percent ; effective rate comes to 5 percent + cess Abetment to be taken if, no cenvat credit is availed on inputs Abetment to be taken if, no cenvat credit is availed on inputs and input services / Benefit of Notification No. 12/2003 not taken. Actual tax to be paid on amount charged,i.e, declared tariff net Actual tax to be paid on amount charged,i.e, declared tariff net of discount, eg, Declared tariff Rs Actual charged Rs Service Tax to be charged on Rs. 1500

12 12 Accommodation Services Accommodation Services Valuation Issues Clarified (Circular No 139/8/2011-TRU Dated ) It is possible to levy separate tariff for the same accommodation in respect of a class of customers which can be recognized as a distinct class on an intelligible criterion. However, it is not applicable for a single or few corporate entities. It is possible to levy separate tariff for the same accommodation in respect of a class of customers which can be recognized as a distinct class on an intelligible criterion. However, it is not applicable for a single or few corporate entities. Where the declared tariff includes the cost of food or beverages, Service Tax will be charged on the total value of declared tariff. But where the bill is separately raised for food or beverages, and the amount is charged in the bill, such amount is not considered as part of declared tariff. Where the declared tariff includes the cost of food or beverages, Service Tax will be charged on the total value of declared tariff. But where the bill is separately raised for food or beverages, and the amount is charged in the bill, such amount is not considered as part of declared tariff. When the declared tariff is revised as per the tourist season, the liability to pay Service Tax shall be only on the declared tariff for the accommodation where the published/printed tariff is above Rupees 1000/-. However, the revision in tariff should be made uniformly applicable to all customers and declared when such change takes place. When the declared tariff is revised as per the tourist season, the liability to pay Service Tax shall be only on the declared tariff for the accommodation where the published/printed tariff is above Rupees 1000/-. However, the revision in tariff should be made uniformly applicable to all customers and declared when such change takes place. For the purpose of service tax, luxury tax has to be excluded from the taxable value (or declared tariff). For the purpose of service tax, luxury tax has to be excluded from the taxable value (or declared tariff).

13 13 Accommodation Services Accommodation Services Per Kerala High Court Order dated in W.P. ( C) No 14054/2011 (E) Kerala Classified Hotels and Resorts Association & Others v Union of India & Others Admitted Interim stay against any coercive steps of recovery of service tax or against any proceedings for imposing penalty for a period of two months in relation to following taxable services- Admitted Interim stay against any coercive steps of recovery of service tax or against any proceedings for imposing penalty for a period of two months in relation to following taxable services- Accommodation Services (zzzzw) Accommodation Services (zzzzw) Restaurant Services (zzzzv ) Restaurant Services (zzzzv )

14 14 Accommodation Services Export /Import of Service for Accommodation / Restaurant ServicesExport Service provided in relation to immovable property situated outside India Service provided in relation to immovable property situated outside IndiaImport Service provided by person from out side India in relation to immovable property situated in India Service provided by person from out side India in relation to immovable property situated in India

15 15 Accommodation Services Person Liable Any hotel, guest house, club etc providing accommodation services for short term to guests are liable to pay service tax. Any hotel, guest house, club etc providing accommodation services for short term to guests are liable to pay service tax.

16 16 Restaurant Services Introduced by Finance Act, 2011 Introduced by Finance Act, 2011 W.e.f. 1 May 2011 (Notification No. 29/2011-ST dated ) W.e.f. 1 May 2011 (Notification No. 29/2011-ST dated ) Section 65(105) (zzzzv) of Finance Act, 1994 Section 65(105) (zzzzv) of Finance Act, 1994 Gross amount charged by the restaurants to customer shall be charged to service tax, subject to abatements/ exemptions. Gross amount charged by the restaurants to customer shall be charged to service tax, subject to abatements/ exemptions.

17 17 Restaurant Services Not defined in statutory provisions Not defined in statutory provisions Literal meaning - a place where people sit and eat meals that are cooked and served on premises Literal meaning - a place where people sit and eat meals that are cooked and served on premises Restaurant means premises in which is carried on principally or wholly the business of supplying meals or refreshments to the public or a class of the public for consumption on the premises but does not include a restaurant attached to a theatre. [Weekly Holidays Act,1942] Restaurant means premises in which is carried on principally or wholly the business of supplying meals or refreshments to the public or a class of the public for consumption on the premises but does not include a restaurant attached to a theatre. [Weekly Holidays Act,1942] Restaurant means any premises, not being a restaurant situated in a hotel in which the business of sale of food or drink to the public is carried on and such premises, at the beginning of any month, are equipped with, or have access to, facilities for air conditioning. [Expenditure Tax Act, 1987]. Restaurant means any premises, not being a restaurant situated in a hotel in which the business of sale of food or drink to the public is carried on and such premises, at the beginning of any month, are equipped with, or have access to, facilities for air conditioning. [Expenditure Tax Act, 1987].

18 18 Restaurant Services Food – Any substance / material consumed to provide nutritional support for the body or for pleasure (Wikipedia) Food – Any substance / material consumed to provide nutritional support for the body or for pleasure (Wikipedia) Nourishing substance that is eaten, drunk or otherwise taken into body to sustain life, provide energy, promote growth; more or less solid nourishment distinct from liquid (American Heritage Dictionary). Beverage – A drink or beverage is a liquid which is specifically prepared for human consumption, fills basic human need, forms part of culture of human society (Wikipedia). Beverage – A drink or beverage is a liquid which is specifically prepared for human consumption, fills basic human need, forms part of culture of human society (Wikipedia). Alcoholic beverage – A drink containing ethanol (alcohol) – beer, wine, spirits; legally consumed world over subject to restrictions. Alcoholic beverage – A drink containing ethanol (alcohol) – beer, wine, spirits; legally consumed world over subject to restrictions.

19 19 Restaurant Services Taxable Service [65(105) (zzzzv)] Any service provided or to be provided to any person, by a restaurant, by whatever name called, having the facility of air-conditioning in any part of the establishment, at any time during the financial year, which has licence to serve alcoholic beverages, in relation to serving of food or beverage, including alcoholic beverages or both, in its premises. Tests for Taxability for Service Provider Restaurant Air Conditioning License to serve alcoholic beverages

20 20 Restaurant Services Legislative Intent The new levy is directed at services provided by high-end restaurants that are air conditioned and have license to serve liquor. Such restaurants provide conditions and ambience in a manner that service provided may assume predominance over the food in many situations. It should not be confused with mere sale of food at any eating house, where such services are materially absent or so minimal that it will be difficult to establish that any service in any meaningful way is being provided. (TRU Letter dated )

21 21 Restaurant Services Essential Features for Taxability Taxable services should have following essential features- a)services shall be provided by a restaurant or any establishment rendering such service and called by whatever name (say, a club, a pub, eating joint fulfilling criteria, coffee houses etc) b)service can be provided to any person c)restaurant should have a facility of air conditioning in whole or any part of the restaurant during any time during the financial year. d)restaurant should have licence to serve alcoholic beverages, whether actually serving such beverages or not. e) eligible restaurants providing services in relation to serving food or beverages including alcoholic beverage, or both in its premises shall be liable to service tax.

22 22 Restaurant Services Air Conditioning Whole or any part of the restaurant to be air conditioned Whole or any part of the restaurant to be air conditioned In case of partial air conditioning – Service Tax applicable on whole of restaurant / services. In case of partial air conditioning – Service Tax applicable on whole of restaurant / services. Not necessary that facility of air conditioning is available round the year. It can be for at any time during the year after Not necessary that facility of air conditioning is available round the year. It can be for at any time during the year after

23 23 Restaurant Services Following Activities / Services are out of Service Tax net Amount paid by customer ex gratia (tip to staff member) Amount paid by customer ex gratia (tip to staff member) Room service Room service Sole of goods at MRP Sole of goods at MRP Service from non AC / non alcohol licensed restaurants Service from non AC / non alcohol licensed restaurants Services from / at outside restaurant premises (if cost centre / profit centre is separate). Services from / at outside restaurant premises (if cost centre / profit centre is separate).

24 24 Restaurant Services CBEC Clarifications (Circular No. 139/8/2011-TRU dated ) Service Tax is leviable on the service provide by a restaurant which satisfies two conditions: (i) it should have the facility of air conditioning in any part of the establishment and (ii) it should have license to serve alcoholic beverages. Within the same entity, if there are more than one restaurant, which are clearly demarcated and separately named, the ones which satisfy both the criteria is only liable to service tax. Service Tax is leviable on the service provide by a restaurant which satisfies two conditions: (i) it should have the facility of air conditioning in any part of the establishment and (ii) it should have license to serve alcoholic beverages. Within the same entity, if there are more than one restaurant, which are clearly demarcated and separately named, the ones which satisfy both the criteria is only liable to service tax. The taxable services provided by a restaurant in other parts of the hotel e.g. swimming pool, or an open area attached to the restaurant are also liable to Service Tax as these areas become extensions of the restaurant. The taxable services provided by a restaurant in other parts of the hotel e.g. swimming pool, or an open area attached to the restaurant are also liable to Service Tax as these areas become extensions of the restaurant. When the food is served in the room, service tax cannot be charged under the restaurant service as the service is not provided in the premises of the air-conditioned restaurant with a licence to serve liquor. Also, the same cannot be charged under the Short Term Accommodation head if the bill for the food will be raised separately and it does not form part of the declared tariff. When the food is served in the room, service tax cannot be charged under the restaurant service as the service is not provided in the premises of the air-conditioned restaurant with a licence to serve liquor. Also, the same cannot be charged under the Short Term Accommodation head if the bill for the food will be raised separately and it does not form part of the declared tariff.

25 25 Restaurant Services Valuation Following exclusions from value allowed – Following exclusions from value allowed – Service charges meant for staff performance (tips) Service charges meant for staff performance (tips) State value added tax State value added tax Other statutory taxes / duties Other statutory taxes / duties Counter sale of goods Counter sale of goods Home delivery charges Home delivery charges 70 percent from gross value including service charges, if no cenvat credit on inputs/ input services availed and benefit of Notification No 12/2003 not taken (Notification No. 34/2011-ST dated ) 70 percent from gross value including service charges, if no cenvat credit on inputs/ input services availed and benefit of Notification No 12/2003 not taken (Notification No. 34/2011-ST dated )

26 26 Health (Medical) Services Introduced by Finance Act 2010 w.e.f [Section 65 (105) (zzzzo)] Introduced by Finance Act 2010 w.e.f [Section 65 (105) (zzzzo)] Vide Notification No. 24/2010-ST dated Vide Notification No. 24/2010-ST dated Withdrawn by Finance Act, 2011 Withdrawn by Finance Act, 2011 Exempted w.e.f vide Notification No 30/2011-ST dated Exempted w.e.f vide Notification No 30/2011-ST dated Coverage into tax net Finance Act, 2010 had introduced the levy of service tax on the following health services- Finance Act, 2010 had introduced the levy of service tax on the following health services- health check up undertaken by hospitals or medical establishment for the employees of business entities (corporate health checkup) health check up undertaken by hospitals or medical establishment for the employees of business entities (corporate health checkup) health service provided under health insurance schemes offered by insurance companies. health service provided under health insurance schemes offered by insurance companies.

27 27 Health (Medical) Services Business Entity [65(19b)] Business entity would include any - Business entity would include any - association of persons association of persons body of individuals body of individuals company, or company, or firm firm Individuals excluded from the scope of business entity. Individuals excluded from the scope of business entity. Definition of taxable service cover the employees of business entity who makes the payment of taxable services. Definition of taxable service cover the employees of business entity who makes the payment of taxable services.

28 28 Health (Medical) Services Taxable Service [Section 65(103) (zzzzo) [prior to ] Any services provided or to be provided by any hospital, nursing home or multi-specialty clinic, Any services provided or to be provided by any hospital, nursing home or multi-specialty clinic, to an employee of any business entity, in relation to health check-up or preventive care, where the payment for such check-up or preventive care is made by such business entity directly to such hospital, nursing home or multi-specialty clinic; or to an employee of any business entity, in relation to health check-up or preventive care, where the payment for such check-up or preventive care is made by such business entity directly to such hospital, nursing home or multi-specialty clinic; or to a person covered by health insurance scheme, for any health check-up or treatment, where the payment for such health check-up or treatment is made by the insurance company directly to such hospital, nursing home or multi- specialty clinic. to a person covered by health insurance scheme, for any health check-up or treatment, where the payment for such health check-up or treatment is made by the insurance company directly to such hospital, nursing home or multi- specialty clinic.

29 29 Health (Medical) Services Essential Conditions for Taxability Services shall be provided by any - Services shall be provided by any - hospital, or hospital, or nursing home, or nursing home, or multi specialty clinic multi specialty clinic Services should be provided to Services should be provided to employees of a business entities, or employees of a business entities, or to a person covered by health insurance scheme. to a person covered by health insurance scheme. In case of service to employees, service may be in relation to health check up / preventive care. In case of service to employees, service may be in relation to health check up / preventive care. In case of persons covered under insurance scheme, service may be in relation to health checkup / treatment In case of persons covered under insurance scheme, service may be in relation to health checkup / treatment Payment shall be made – Payment shall be made – employer being business entity employer being business entity by directly insurance company, but by directly insurance company, but not by employee or insured person. not by employee or insured person.

30 30 Health (Medical) Services Scope of Services corporate health check up schemes corporate health check up schemes medi -claim insurance policies (cash less polices) medi -claim insurance policies (cash less polices) regular check up of employees such as in hotels/ airlines/ IT industry etc. regular check up of employees such as in hotels/ airlines/ IT industry etc. health / medical perquisites by employers such as for employees wherein employees bears the cost. health / medical perquisites by employers such as for employees wherein employees bears the cost.

31 31 Health (Medical) Services Services when not taxable The service shall not be taxable in the following circumstances- service provider is not a hospital, nursing home or multi specialty clinic. service provider is not a hospital, nursing home or multi specialty clinic. service provider is an individual doctor or an in-house doctor service provider is an individual doctor or an in-house doctor service provider is a hospital belonging to same business entity whose employee is being provided service service provider is a hospital belonging to same business entity whose employee is being provided service preventive care in case of insured person preventive care in case of insured person Payment made by the patient or individuals Payment made by the patient or individuals Payment made by the insured person and later reimbursed by the insurance company Payment made by the insured person and later reimbursed by the insurance company

32 32 Health (Medical) Services Amendments made by Finance Act, 2011 Clinical Establishment (Section 65(25a)] Clinical establishment means ­ a hospital, maternity home, nursing home, dispensary, clinic, sanatorium or an institution, by whatever name called, owned, established, administered or managed by any person or, body of persons, whether incorporated or not, having in its establishment the facility of central air- conditioning either in whole or in part of its premises and having more than twenty-five beds for in-patient treatment at any time during the financial year, offering services for diagnosis, treatment,pr care for illness, disease, injury, deformity, abnormality, or pregnancy in any system of medicine; or a hospital, maternity home, nursing home, dispensary, clinic, sanatorium or an institution, by whatever name called, owned, established, administered or managed by any person or, body of persons, whether incorporated or not, having in its establishment the facility of central air- conditioning either in whole or in part of its premises and having more than twenty-five beds for in-patient treatment at any time during the financial year, offering services for diagnosis, treatment,pr care for illness, disease, injury, deformity, abnormality, or pregnancy in any system of medicine; or an entity owned, established, administered or managed by any person or body of persons, whether incorporated or not, either as an independent entity or as a part of any; clinical establishment referred to in sub-clause (I), which carries out diagnosis of diseases through pathological, bacteriological, genetic, radiological, chemical, biological investigations or other diagnostic or investigative services with the aid of laboratory or other medical equipment, an entity owned, established, administered or managed by any person or body of persons, whether incorporated or not, either as an independent entity or as a part of any; clinical establishment referred to in sub-clause (I), which carries out diagnosis of diseases through pathological, bacteriological, genetic, radiological, chemical, biological investigations or other diagnostic or investigative services with the aid of laboratory or other medical equipment, But does not include an establishment, owned or controlled by – the Government; or the Government; or a local authority; a local authority;

33 33 Health (Medical) Services Taxable Service [Section 65 (105) (zzzzo)] Services provided or to be provided to any person, - by a clinical establishment; or by a clinical establishment; or by a doctor, not being an employee of a clinical establishment, who provides services from such premises for diagnosis, treatment or care for illness, disease, injury, deformity, abnormality or pregnancy in any system of medicine; by a doctor, not being an employee of a clinical establishment, who provides services from such premises for diagnosis, treatment or care for illness, disease, injury, deformity, abnormality or pregnancy in any system of medicine; Taxable services include- Any service provided by a clinical establishment having the facility of central air­ conditioning in any part of the establishment and more than 25 beds for in-patient treatment at any time of the year; Any service provided by a clinical establishment having the facility of central air­ conditioning in any part of the establishment and more than 25 beds for in-patient treatment at any time of the year; Diagnostic services provided by a clinical establishment with the aid of laboratory or medical equipment; and Diagnostic services provided by a clinical establishment with the aid of laboratory or medical equipment; and Health-related services provided by doctors, not being employees, providing health-related services from the premises of a clinical establishment. Health-related services provided by doctors, not being employees, providing health-related services from the premises of a clinical establishment.

34 34 Health (Medical) Services Withdrawal/ specific Exemption Taxable services provided under clause (zzzzo) shall be exempt from whole of Service tax w.e.f vide Notification No. 30/2011 – ST dated Taxable services provided under clause (zzzzo) shall be exempt from whole of Service tax w.e.f vide Notification No. 30/2011 – ST dated Service tax not applicable on health (medical ) services w.e.f , not even to services covered under pre Finance Act, 2011 provisions Service tax not applicable on health (medical ) services w.e.f , not even to services covered under pre Finance Act, 2011 provisions

35 35 Health (Medical) Services Legal Position after exemption Old provisions of clause zzzzo hold good till only as from , Finance Act, 2011 was enacted and clause zzzzo substituted. Old provisions of clause zzzzo hold good till only as from , Finance Act, 2011 was enacted and clause zzzzo substituted. But amended definition is effective from But amended definition is effective from Between and (both dates included), there is no taxable service as such under clause zzzzo. Between and (both dates included), there is no taxable service as such under clause zzzzo. W.e.f , services under clause zzzzo are fully exempt vide Notification 30/2011-ST dated W.e.f , services under clause zzzzo are fully exempt vide Notification 30/2011-ST dated Will old definition continue till – No. Will old definition continue till – No.

36 36 THANK YOU FOR YOUR PRECIOUS TIME AND ATTENTION Dr. Sanjiv Agarwal FCA, FCS, Jaipur


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