Full Judgment Text
* IN THE HIGH COURT OF DELHI AT NEW DELHI
% Judgment reserved on : 29 August 2023
Judgment pronounced on: 06 September 2023
+ SERTA 10/2023
COMMISSIONER OF CENTRAL TAX ..... Appellant
Through: Ms. Sonu Bhatnagar, SC along with
Ms. Monica Benjamin and Ms.
Nishtha Mittal, Advs.
versus
M/S SINGTEL GLOBAL INDIA PVT LTD ..... Respondent
Through: Mr. Kamal Sawhney, Mr. Krishna
Rao and Ms. Aakansha Wadhwani,
Advs.
+ SERTA 11/2023
COMMISSIONER OF CENTRAL TAX ..... Appellant
Through: Ms. Sonu Bhatnagar, SC along with
Ms. Monica Benjamin and Ms.
Nishtha Mittal, Advs.
versus
M/S SINGTEL GLOBAL INDIA PVT LTD ..... Respondent
Through: Mr. Kamal Sawhney, Mr. Krishna
Rao and Ms. AakanshaWadhwani,
Advs.
+ SERTA 12/2023
COMMISSIONER OF CENTRAL TAX ..... Appellant
Through: Ms. Sonu Bhatnagar, SC along with
Ms. Monica Benjamin and Ms.
Nishtha Mittal, Advs.
versus
M/S SINGTEL GLOBAL INDIA PVT LTD ..... Respondent
Through: Mr. Kamal Sawhney, Mr. Krishna
Rao and Ms. AakanshaWadhwani,
Advs.
CORAM:
HON'BLE MR. JUSTICE YASHWANT VARMA
HON'BLE MR. JUSTICE DHARMESH SHARMA
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Signature Not Verified
Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
18:18:18
J U D G M E N T
DHARMESH SHARMA, J.
1. This common judgment shall decide the above-noted three
Service Tax Appeals (for short „STA‟) filed by the appellant in terms
1
of Section 35G of the Central Excise Act, 1944 read with Section 83
2
of the Finance Act, 1994 along with Section 174 of the Central Goods
3
and Services Tax Act, 2017 which are directed against a common
Final Order passed by the Customs, Excise and Service and Service
4
Tax Appellate Tribunal dated 07 December 2022. In terms of the said
order the CESTAT had dismissed three separate appeals preferred by
the appellant viz. STAs Nos. 52609/2019, 52682/19 and 50023/2020
directed against the common order passed by the Commissioner
(Appeals). The sum result of the aforesaid orders is that refund
5
claimed by the respondent, M/s. SingTel Global (India) Pvt. Ltd.
under Rule 5 of the CENVAT Credit Rules, 2004 read with the Place
6
of Provision of Service Rules, 2012 , of the unutilized input service
credit of input services by SGIPL towards export of
telecommunication services to Singapore Telecommunication
7
Limited located in Singapore has been allowed.
FACTUAL BACKGROUND:
2. In order to clarify the factual background, it is relevant to take
note that the Commissioner (Appeals) vide order dated 31 January
1
CE Act
2
Fin. Act
3
CGST Act
4
CESTAT
5
SGIPL
6
POPS Rules
7
SingTel
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Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
18:18:18
2019 upheld the order dated 18 June 2017 passed by the Assistant
Commissioner allowing a refund claim of Rs.1,32,70,532/- for the
period July, 2015 to September, 2015 in favour of the SGIPL and the
appeal filed by the Revenue was dismissed, which was challenged by
the appellant in appeal No. 52609/2019.
3. However, in the other two appeals, there is a slight twist to the
tale inasmuch as the Assistant Commissioner declined the claim for
refund by SGIPL and on challenge the Commissioner (Appeals) vide
order dated 05 July 2019 set aside the order dated 23 October 2018
passed by the Assistant Commissioner and allowed the refund claim
of Rs. 8,69,82,565/- for the period October, 2015 to December, 2016,
which led to filing of appeal No.52682/2019 by the appellant.
Similarly, the Commissioner (Appeals) passed an order dated 31
October 2019 thereby setting aside order dated 23 July 2019 passed by
the Assistant Commissioner by which refund claim of Rs.
3,30,37,934/- for the period January, 2017 to June, 2017 claimed by
the SGIPL was rejected, which led to the appellant filing STA No.
50023/2019. The three appeals were disposed of by the impugned
common order dated 07 December, 2022, whereby it was held that
SGIPL is not an „intermediary‟ and was entitled to refund towards the
CENVAT credit for the period in question i.e., July, 2015 to June,
2017.
4. The aforesaid decisions arose in the background of SGIPL,
which is a company based in India, being engaged in providing global
telecommunication and ancillary support services, and it is claimed
that part of its services is also exported. It entered into an agreement
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Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
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dated 14 July 2011 with SingTel, which is a licensed
telecommunications service provider in Singapore. The aforesaid
agreement envisaged SGIPL providing necessary infrastructure in
India so as to enable SingTel to facilitate seamless global
telecommunication services to its customers based in Singapore and
other foreign territories.
5. The plea of the appellant in each of the matters as also
canvassed before this Court, has been that SGIPL merely procures
services from other service providers in India viz., Airtel, Vodafone,
Tata, Reliance etc. and supplies the same to Singtel without any
alteration; and that SGIPL does not provide the aforesaid services of
telecommunications “ on their own account” and thus fall within the
definition of „intermediary services‟ on a conjoint reading of Rule
8
6A(1)(d) of the Services Tax Rules read with Rule 9(C) of the POPS
Rules.
6. Per contra, SGIPL contends that the place of provision of
services would be considered as per the location of the recipient of
services by virtue of Rule 3 of the ST Rules, which is outside India,
and that it is not an „intermediary‟.
7. In a nutshell, learned CESTAT vide the impugned common
order dated 07 December 2022 interpreted the terms and conditions
of the agreement dated 14 July 2011 executed between SGIPL and
SingTel and in light of relevant statutory rules as well as the decision
of this Court in the case of Verizon Communications India Ltd. v.
8
ST Rules
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Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
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9
Assistant Commissioner of ST, Delhi-III besides the decision of the
CESTAT itself in M/s. Black Rock Service India Private Ltd. v.
10
Commissioner of CGST , held that there was no scope for doubt
that services provided by SGIPL do not qualify as „intermediary
services‟ and the services are provided by it out of its own account to
SingTel. Accordingly, SGIPL has been held entitled to claim refund
totalling Rs. 13,32,91,031/- for the period July, 2015 to June, 2017
towards CENVAT credit.
8. On filing of the instant appeals before this Court, advance
notice was issued to the respondent and the learned counsel for the
respondent has opposed the appeals. Ms. Sonu Bhatnagar, learned
Standing Counsel for the appellant has vehemently urged that in terms
of Rule 9 of the POPS Rules, the place of provision of services is
stipulated to be the location of the service provider and on a combined
reading of the said provision along with Rule 2(f) of the POPS Rules
which defines the expression „intermediary services‟, would show that
the provisions for „intermediary services‟ cannot be considered as
export of service particularly when it is considered that SGIPL is
merely arranging or facilitating the main service of telecommunication
services from the Indian telecom operators to Singtel in its original
form and not providing the main service of telecommunication
services on their own account, thereby charging handling fee and
getting charges reimbursed on actual basis from SingTel.
9
2018 (8) GSTL 32 (Del.)
10
Service Tax Appeal No. 61877/2018 decided on 08 August 2022
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Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
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9. Learned Standing Counsel has urged that the impugned order
passed by the learned CESTAT raises the following issues:-
(a) Whether the services provided by the respondent are covered under
„export of services‟?
(b) Whether the services provided by the respondent qualify as
„intermediary services‟?
(c) Whether the respondent is entitled to refund of unutilised
CENVAT credit under Rule 5 of Cenvat Credit Rules 2004?
10. It was further canvassed that reliance on the decision Verizon
Communications India Ltd. (supra) was misplaced since the SLP
filed by the Revenue against the said decision has been admitted for
hearing by the Hon'ble Supreme Court. It was also pointing out that
Verizon India has in fact admitted their liability under Sabka
11
Vishwas (Legacy Dispute Resolution) Scheme, 2019 and is no
longer a party to the pending SLP proceedings. It was urged that the
substantial question of law that arises for consideration in the present
appeals is also sub-judice for consideration before the Apex Court in a
batch of SLPs filed by the Revenue as well other concerned parties.
ANALYSIS AND REASONS FOR DECISION
11. Having bestowed our thoughtful consideration to the
submissions advanced by the learned counsel for the parties and on
perusal of the record, at the outset, we find that the instant appeals
preferred by the appellant are devoid of any merits. First things first,
although it does appear that the decision in Verizon Communications
India Ltd. (supra) and other connected Writ Petitions have been
assailed by the parties concerned before the Apex Court, yet there is
no stay order in favour of the department/appellant, and therefore,
11
SVLDRS
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Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
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there is no bar in this Court to consider the broad issues raised in the
present appeals, for which reference can be made to decisions in
12
Kunhayammed and Others v. State of Kerala , wherein the legal
impact of pendency of the special Leave petition was explained as
under:
“(1) While hearing the petition for special leave to appeal, the
Court is called upon to see whether the petitioner should be granted
such leave or not. While hearing such petition, the Court is not
exercising its appellate jurisdiction; it is merely exercising its
discretionary jurisdiction to grant or not to grant leave to appeal.
The petitioner is still outside the gate of entry though aspiring to
enter the appellate arena of the Supreme Court. Whether he enters
or not would depend on the fate of his petition for special leave;
(2) If the petition seeking grant of leave to appeal is dismissed, it is
an expression of opinion by the Court that a case for invoking
appellate jurisdiction of the Court was not made out;
(3) If leave to appeal is granted the appellate jurisdiction of the
Court stands invoked; the gate for entry in the appellate arena is
opened. The petitioner is in and the respondent may also be called
upon to face him, though in an appropriate case, in spite of having
granted leave to appeal, the Court may dismiss the appeal without
noticing the respondent.
(4) In spite of a petition for special leave to appeal having been
filed, the judgment, decree or order against which leave to appeal
has been sought for, continues to be final, effective and binding as
between the parties. Once leave to appeal has been granted, the
finality of the judgment, decree or order appealed against is put in
jeopardy though it continues to be binding and effective between
the parties unless it is a nullity or unless the Court may pass a
specific order staying or suspending the operation or execution of
the judgment, decree or order under challenge.”
12. Reverting back to the instant appeals, it would be expedient to
take note of the relevant statutory provisions. Rule 6(A) of the ST
Rules provides as under:-
"6A.Export of services. -
(1) The provision of any service provided or agreed to be provided
shall be treated as export of service when,-
12
(2000) 6 SCC 359
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KUMAR VATS
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(a) The provider of service is located in the taxable territory,
(b) the recipient of service is located outside India,
(c) the service is not a service specified in the section 66D of the
Act,
(d) the place of provision of the service is outside India,
(e) the payment for such service has been received by the provider
of service in convertible foreign exchange, and
(f) the provider of service and recipient of service are not merely
establishments of a distinct person in accordance with item(b) of
Explanation 3 of clause (44) of section 65B of the Act.
(2) Where any service is exported, the Central Government may,
by notification, grant rebate of service tax or duty paid on input
services or inputs, as the case may be, used in providing such
service and the rebate shall be allowed subject to such safeguards,
conditions and limitations, as may be specified, by the Central
Government, by notification. "
13. Further, Rule 3 of the POPS Rules provides as under:
"3. Place of provision generally.-
The place of provision of a service shall be the location of the
recipient of service:
Provided that in case of services other than online information and
database access or retrieval services, where the location of the
service receiver is not available in the ordinary course of business,
the place of provision shall be the location of the provider of
service. "
14. Thus, as per Rule 6(A), the provision of service shall be treated
as export of service when the place of provision of service is outside
India . As per Rule 3 of the POPS Rules, the place of provision of a
service shall be the location of the recipient of service . However,
vide Rule 9(c) of POPS Rules, the place of provision for
“Intermediary services” would be the location of the service provider.
The term "intermediary" has been defined in rule 2(f) as follows:
" 2(f) Intermediary' means a broker, an agent or any other person,
by whatever name called, who arranges or facilitates a provision of
a service (hereinafter called the 'main' service) or a supply of
goods, between two or more persons, but does not include a person
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Signature Not Verified
Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
18:18:18
who provides the main service or supplies the goods on his
account."
15. It is pertinent to mention here that vide a communication dated
16 March 2012 by the Department of Revenue (Tax Research Unit),
the term "Intermediary” services has been explained as follows :
"3.7.7 What are "Intermediary Services"?
An "intermediary" is a person who arranges or facilitates a supply
of goods, or a provision of service, or both, between two persons,
without material alteration or further processing. Thus, an
'intermediary' is involved with two supplies at any one time:
(i) the supply between the principal and the third party; and
(ii) the supply of his own service (agency service) to his
principal, for which a fee or commission is usually charged.
For the purpose of this rule, an 'intermediary' In respect of goods
(commission agent le a buying or selling agent) is excluded by
definition.
In order to determine whether a person is acting as an Intermediary
or not, the following factors need to be considered:-
Nature and value: An „intermediary‟ cannot alter the nature or
value of the service, the supply of which he facilitates on behalf of
his principal, although the principal may authorize the
„intermediary‟ to negotiate a different price. Also, the principal
must know the exact value at which the service is supplied (or
obtained) on his behalf, and any discounts that the 'intermediary'
obtains must be passed back to the principal.
Separation of value: The value of an intermediary's service is
invariably identifiable from the main supply of service that he is
arranging. It can be based on an agreed percentage of the sale or
purchase price. Generally, the amount charged by an agent from
his principal is referred to as "commission".
Identity and title: The service provided by the intermediary on
behalf of the principal are clearly identifiable.
In accordance with the above guiding principles, services provided
by the following persons will qualify as "Intermediary services:-
(i) Travel Agent (any mode of travel)
(ii) Tour Operator
(iii) Stockbroker
(iv) Commission agent [an agent for buying or selling of goods is
excluded
(v) Recovery Agent
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Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
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Even in other cases, wherever a provider of any service acts as an
agent for another person, as identified by the guiding principles
outlined above, this rule will apply."
16. A careful perusal of Rule 2(f) shows that an entity or person to
qualify as an "intermediary" must be shown to work as a broker, an
agent or any other person, by whatever name called, who arranges or
facilitates a provision of a service to be called the main service or a
supply of goods, between two or more persons, but does not include a
person who provides the main service or supplies the goods on his
own account. The communication dated 16 March 2012 referred to
above, also clarifies that an intermediary service is involved with two
supplies at any one time namely:
(i) the supply between principal and the third party;
(ii) the supply of his own service (agency service) to his
principal, for which a fee or commission is usually charged.
17. It is borne out from the record that while SingTel is a licensed
telecommunication service provider in Singapore and on its own as
well through a network of affiliates or suppliers, is engaged in
providing telecommunication services to its registered consumers in
Singapore and other foreign territories. On the other hand SGIPL, is a
licensed provider of certain telecommunication services in India,
which has undertaken to ensure seamless global telecommunication
services to the customers registered with SingTel in Singapore and
elsewhere. At this juncture, it would be expedient to refer to the
relevant clauses/stipulations in the agreement dated 14 July 2011
executed between the parties, that read as under:-
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Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
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“3. Scope of Agreement
3.1 SGIPL agrees to supply and SingTel agrees to procure from
SGIPL the Service in accordance with the terms and conditions of
this Agreement .
3.2 SingTel shall place an order for such Services in the format
mutually agreed by both parties from time to time.
4. Responsibilities of SGIPL
4.1 SGIPL shall provide or use its reasonable endeavors to procure
Service in India as ordered by SingTel.
4.2 SGIPL shall provide the Services when SingTel's Customers
require the services originating in Territories and terminating in
India .
4.3 SGIPL shall provide at its own expense, all facilities and
resources whatsoever necessary to enable SGIPL to provide the
Services to SingTel .
4.4 SGIPL shall provide to SingTel customer care, customer
support (including assistance to a Customer in matters relating
telecommunications access, data entry and data retrieval to and
from the Services provided hereunder) and other services as may
be reasonably required by SingTel from time to time.
4.5 SGIPL shall maintain detailed records and other supporting
documentation associated with the provision of the Services.
4.6 SGIPL shall provide the Services in accordance with the terms
and conditions of its telecom licenses and all applicable laws .
4.7 SGIPL shall bill on SingTel for the Services provided by
SGIPL.
5. Responsibility of SingTel
5.1 SingTel shall, whether itself or through its distributors or
suppliers, provide, operate, maintain and manage all ILCs and
network equipment in the Territories.
5.2 SingTel shall also bear the exchange risk realizable and arising
from any transactions transacted in foreign currency and similarly
will be remunerated fully for any realised exchange gains
attributable to SGIPL.
5.3 When SingTel submits an order for the Services, SingTel must
submit a Letter of Undertaking signed by the End User Customer
in India In the form attached as [Schedule C) attached.
5.4 SingTel and SGIPL shall each be responsible for all planning,
design and capacity management activities required for its
respective network, including associated bandwidth, to support the
launch and delivery of Services. This includes responsibility for
any future enhancements and changes to the network.
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Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
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6. Charges and Payment
6.1 Service provided by SGIPL will be charged at market prices
exclusive of any applicable Indirect tax, which will be separately
levied and payable by SingTel .
6.2 SGIPL will invoice SingTel for the Services by the end of the
month following the month of the provision of Services.
6.3 SingTel will be required to pay such monthly invoices within
30 days of the date of such monthly invoices (or upon such other
basis as the parties may mutually agree from time to time).
6.4 The Invoice shall be in US dollars and shall be accompanied by
a statement detailing the Services to which the Invoice relates. Any
changes to SGIPL's prices must be notified in writing to SingTel
and will be applicable to those Services supplied after the date of
serving such notice.
6.6 Notwithstanding that the above invoices are rendered, both
parties agree that transfer pricing adjustments to prices may be
made at any time in order to ensure that prices are at acceptable
arm's length in accordance with transfer pricing legislation in the
applicable country . Such transfer pricing adjustments may be
computed on an aggregated basis (rather than identified to a
specific transaction). When such adjustments are made by SGIPL
to increase the price. SingTel agrees to pay the additional amounts
including any applicable Indirect taxes. Where such adjustments
result in a lower price, SGIPL will refund the applicable amounts
to SingTel.
xxxxxxxxxx
19. Independent Contractor
19.1 The Relationship of the parties to this Agreement shall always
and only be that of Independent contractors and nothing in this
Agreement shall create or be deemed to create a partnership or the
relationship of principal and agent or employer and employee
between the parties.”
18. On a careful perusal of the terms and conditions of the
aforesaid Agreement dated 14 July 2011 between SingTel and SGIPL,
we find no legal infirmity or irrational approach adopted by the
learned CESTAT when it comes to conclude that SGIPL is not
providing „intermediary services‟. The plea that SGIPL is not
providing any services on its own account is misplaced. It is manifest
that there is no contract between SingTel and service providers in
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KUMAR VATS
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India like Airtel, Vodafone, Reliance etc., and the agreement between
SGIPL and SingTel is on principal-to-principal basis. Indeed, SGIPL
has entered into separate contracts with the telecom operators in India
but on its own account and not as in the nature of a broker or agent for
SingTel. The above-referred communication dated 16 March 2012
also supports such a disposition. The agreement envisages that SGIPL
has to provide, at its own expenses, all necessary infrastructure in
order to provide the services to SingTel and its customers. It further
envisages that SGIPL shall raise invoices upon SingTel in US dollars
for the services rendered on a monthly basis and on such transfer
prices as may be agreed upon from time to time. Clause 19 of the
Agreement specifically stipulates that the relationship of the parties to
the Agreement shall always and only be that of independent
contractors and nothing in the Agreement shall create or be deemed to
create a partnership or the relationship of principal and agent or
employer and employee between the parties. Incidentally, the
appellant has not even alleged that the aforesaid agreement is a
camouflage, fraudulent or designed to get over the service tax dragnet.
19. In the end, in so far as the decision in Verizon Communications
India Ltd. (supra) , the factual narration reads that Verizon India had
entered into a Master Supply Agreement with Verizon US for
rendering connectivity services for the purpose of data transfer to the
end user based in USA. The issue that came to be was addressed by
the Co-ordinate Bench was: whether the telecommunication services
provided by Verizon India for the period in question amounted to
„export of services‟ within the meaning of Rule 6(A) of the ST Rules.
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KUMAR VATS
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This was answered in the affirmative. It was held that since the
recipient of the service Verizon US was outside India, Verizon India
rightly treated it as an „export of service‟ and accordingly it was
exempted from the liability of paying service tax. It was pointed out
that the „recipient‟ of services is determined by the contract between
the parties and this would depend on who has the contractual right to
receive the services and who is responsible for the payment for the
services provided to the service recipient; there was no privity of
contract between Verizon India and the customers of Verizon US;
while such customers may be 'users' of the services provided by
Verizon India but were not its recipients; even though Verizon India
may have been using the services of a local telecom operator but that
would not mean that the services to Verizon US were being rendered
in India; and the place of provision of such service to Verizon US
remains outside India. It is pertinent to mention that a reference was
made to the decision of the Apex Court in the case of All India
13
Federation of Tax Practitioners v. Union of India , wherein the
nature of service tax was explained and it was observed that:
“6. At this stage, we may refer to the concept of “Value Added
Tax” (VAT), which is a general tax that applies, in principle, to all
commercial activities Involving production of goods and provision
of services. VAT is a consumption tax as It is borne by the
consumer.
7. In the light of what is stated above, it is dear that Service Tax is
a VAT which in turn is destination based consumption tax in the
sense that it is on commercial activities and is not a charge on the
business but on the consumer and it would, logically, be leviable
only on services provided within the country. Service tax is a value
added tax”.
13
2007 (7) STR 625 (SC)
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20. Without further ado and applying the same analogy to these
matters, we find that the submissions advanced by the learned
Standing counsel for the appellant overlooks the fact that the recipient
of services is based outside India. At the cost of repetition it may be
stated that SGIPL apart from facilitating main service of
telecommunication services also provides services of customer care
and customer support services to the end consumers based in
Singapore and foreign territories registered with SingTel Singapore in
matters relating to telecommunication, access, data entry and data
retrieval. SingTel has no contract with telecom service providers in
India and the end consumers are based in Singapore and other foreign
territories covered by SingTel and are independently entitled to
demand service from SingTel and pay for the services accordingly to
it too.
21. Before parting with the instant appeals, our attention has been
drawn to the earlier round of litigation between the parties with regard
to refund applications moved by SGIPL under Section 11B of the CE
Act as made applicable to the Service Tax vide Section 83 of the Fin.
Act and which had led to a decision by a Co-ordinate Bench of this
14
Court in SingTel Global (India) Pvt. Ltd. v. Union of India
whereby for the same period i.e. July, 2015 to June, 2017 after the
appeal was allowed by the Commissioner (Appeals) vide order dated
05 July 2019 (subject matter of ST Appeal No. 56682/19), the
Assistant Commissioner while processing the claim of SGIPL for
14
WP (C) No. 8876/2021 decided on 14.12.2022: (2023) 2 centax 203 (Del)
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refund of input tax for the aforesaid rather questioned the decision of
the Commissioner (Appeals) in allowing the claim of the SGIPL for
unutilized CENVAT Credit inter alia observing that the decision in
Verizon Communications India Ltd. (supra) was flawed and there
was already an appeal pending against the view expressed therein
before the Apex Court. Suffice it to note that the said action on the
part of the Assistant Commissioner in trying to overreach the orders
passed by the superior authority was deprecated by our Court and
inter alia a passing reference was made that the view that SGIPL is a
provider of „intermediary services‟ was not correct and there was no
option but for the Revenue to await the outcome of the appeals
preferred by them before the learned CESTAT. It was simultaneously
observed that by that time even the learned CESTAT had also
dismissed the appeals, presumably vide the impugned order dated 07
December 2022.
22. In view of the aforesaid discussion, we find that the present
appeals are bereft of any merit. Accordingly, the same are dismissed.
YASHWANT VARMA, J.
DHARMESH SHARMA, J.
September 06, 2023
Sadique
SERTA 10/2023; 11/2023 and 12/2023 Page 16 of 16
Signature Not Verified
Digitally Signed By:PRAMOD
KUMAR VATS
Signing Date:06.09.2023
18:18:18