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Case lawHigh Court › DIT v Mitchell Drilling International Pvt Ltd
High CourtHelps taxpayers.44BBs.44BB(1)s.44BB(2)s.44BB(3)s.194-Is.194J

DIT v Mitchell Drilling International Pvt Ltd

The officer has added the service tax we collected from ONGC to our s.44BB gross receipts. Is that right?

The officer has added the service tax we collected from ONGC to our s.44BB gross receipts. Is that right?

No. Service tax collected by the assessee and passed on to the Government is not to be included in the gross receipts under s.44BB(2) read with s.44BB(1). It is not an amount paid or payable, or received or deemed to be received, for the services rendered — the assessee is only a collecting agency.

Decided by the High Court (Dr. S. Muralidhar J and Vibhu Bakhru J) on 2015-09-28, reported as ITA Nos. 403/2013 and 384/2015 (High Court of Delhi). It bears on section 44BB, section 44BB(1), section 44BB(2), section 44BB(3), section 194-I, section 194J of the Income Tax Act 1961, in Presumptive Taxation & Audit and How Tax Law Is Read matters.

Still good law. The Full Bench of the Uttarakhand High Court in DIT v. M/s Schlumberger Asia Services Ltd. (12 April 2019), which was read in full for this entry, recorded at paragraph 61 that no appeal had been preferred by the Revenue to the Supreme Court against this judgment, and at paragraph 62 declined to differ from it. Beyond that Full Bench, later treatment has not been checked.

Why it matters

At a ten per cent deemed margin, every rupee of indirect tax swept into the gross receipts is taxed as if it were margin, so this point is worth roughly ten per cent of the tax collected multiplied by the rate. The reasoning is that the words in s.44BB(2)(a) and (b) — amount paid or payable, and amount received or deemed to be received — are qualified by the words on account of the provision of services and facilities, so only amounts paid for the services can enter the computation. That reasoning is about the character of an indirect tax collected for the Government and is not confined to the Finance Act 1994 levy; but this judgment is about service tax, it was decided in 2015, and no court has been shown to me deciding the same point for GST, so a GST argument has to be run on the reasoning rather than on the holding. The Revenue's counter-authorities — Chowringhee Sales Bureau and George Oakes — were held to have been decided in their own specific contexts.

Binding within that High Court's jurisdiction. Persuasive elsewhere.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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Related

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