Case Law Details

Case Name : Kusum Healthcare Pvt Ltd. Vs Commissioner of Central Excise &
Appeal Number : Service Tax (CESTAT Delhi)
Date of Judgement/Order : Service Tax Appeal No. 53015 of 2016
Related Assessment Year : 01/10/2021

Kusum Healthcare Pvt Ltd. Vs Commissioner of Central Excise & Service Tax (ITAT Delhi)

Facts- M/s Kusum Healthcare has preferred an appeal challenging OIO demanding tax on the finding that remittances made to their branches and offices abroad is ‘consideration’ for ‘taxable service’ procured from outside the taxable territory.

Conclusion- The Tribunal in the case of Milind Kulkarni has held that deeming provision in a statue is a temporary suspension of conventional wisdom and existing legislative formulation of a concept or situation for a specified purpose and that the graft so incorporated is intended to be applied in its entirety and within the intended context.

It, then, went on to enunciate the purpose of deeming demutualization as a contrivance to assure that structuring of such dependent establishments would not provide an avenue for escapement, either overtly or covertly, from the enforcement of the levy on the ‘taxable event’; concomitantly, the deemed demutualization does not demonstrate legislative intent to tax transactions that are normal to such dependent existence.

FULL TEXT OF THE CESTAT DELHI ORDER

M/s Kusum Healthcare Ltd has filed this appeal challenging order-in-original no. ALW-EXCUS-OIO-COM-32/16-17 dated 25th August 2016 of Commissioner of Central Excise, Alwar demanding tax of ₹ 4,28,30,862 for 2014-15 on the finding that remittances made to their branches and offices abroad was ‘consideration’ for ‘taxable service’ procured from outside the ‘taxable territory’ which, according to Learned Counsel for appellant, is inconsistent with decisions of the Tribunal in which demands on identical grounds for the preceding periods had been set aside. The interest liability under section 75 of Finance Act, 1994 as well as penalty under section 76 and section 77 of Finance Act, 1994 are also sought to be quashed. Another submission in the grounds of appeal, though not pressed in the light of these binding precedents, is that their explanation of these remittances as payments for supplies procured by overseas branches and offices, which would have excluded them from being deemed to have received in the ‘taxable territory’, was not considered in the impugned order that, according to Learned Counsel, was further susceptible for having been founded on statutory provisions and Rules that had ceased to be in vogue by then.

2. A narration of the factual matrix may not, therefore, be inappropriate. Appellant is a ‘export oriented unit (EOU)’ approved under the eponymous scheme in the Foreign Trade Policy for production and export of ‘pharmaceutical products’ and, in pursuit of its business strategy, has established representative offices at several places outside the country, as ‘cost centres’, dependent on the principal establishment in India for operational existence. By taking recourse to the special design in Finance Act, 1994, intended for taxing recipients as ‘deemed provider’ of services received from abroad, to the transfer of funds as recorded in the books of accounts, the jurisdictional service tax authority initiated proceedings for recovery, initially for the extended period between April 2006 and March 2011 and, thereafter, at regular intervals which culminated in adjudication orders of which two, chronologically preceding the one now impugned before us, were set aside in Kusum Healthcare Ltd v. Commissioner of Central Excise1 and in Kusum Healthcare Ltd v. Commissioner of Central Excise, Alwar2.

3. Learned Counsel for the appellant relies on these two decisions to contend that that no demand, and attendant statutory detriment, lies against them for the period of dispute in the present proceedings too. He pointed out that the first of the orders, pertaining to the pre-‘negative list’ era, has held that the nature of the relationship of overseas branches with the principal office does not render their internal transactions amenable to coverage as ‘consideration’ merely by concatenation of financial flows and the clarification afforded by Explanation 1 in section 66A of Finance Act, 1994 without setting forth positive evidence of ‘taxable service’ having been rendered within the meaning of Taxation of Services (Provided from Outside India and Received in India) Rules, 2006. The second of the two, according to him, drew from the principles that the first was founded upon to hold that the re-statement of the legislative intent to tax import of services, through the Place of Provision of Service Rules, 2012 read with section 66B of Finance Act, 1994, did not alter the non-applicability of the levy to the flow of funds from the principal office to the branches. Learned Counsel also submitted that their response to the notice highlighting several transactions as related to goods, or otherwise beyond the reach of levy intended in Finance Act, 1994, had not been appreciated in the proper perspective by the adjudicating authority.

4. Learned Authorised Representative reiterated the contents of the impugned order and pointed out that the transactions were taxable within the authority of section 66B of Finance Act, 1994 in accordance with the provisions of the relevant Rules framed for placement of performance of service within, or without, the ‘taxable territory’ in the ‘negative list’ regime.

5. The controversy in taxing of intangibles, fraught with obvious handicap of lack of visibility, is compounded when it comes to the imperative of bestowing ‘national treatment’ to services sourced from abroad owing to impossibility of ascertaining arrival at the territorial boundary. The saddling of demand on the one manifest aspect of service transactions, viz., ‘consideration’, without contextual reference to the taxable event, though irresistibly attractive to tax authorities, may not always be consistent with legislative intent. That has been the thrust of decisions of the Tribunal in several disputes arising from the fastening of tax liability in cross-border transactions. The conceptual clarity of legislative intent essential for resolution of this conundrum, and provided by the exposition in Torrent Pharmaceuticals v. Commissioner of Service Tax, Ahmadabad3 and in Milind Kulkarni & others v. Commissioner of Central Excise, Pune4, was relied upon thus

‘6. We find that the Revenue has taken a stand that since as per the proviso, a branch office located outside India shall be treated as a separate business establishment, the services rendered by such establishment should be treated for tax liability. In this connection, we note, similar dispute came before the Tribunal for tax liability under the very same tax entry in Torrent Pharmaceutical Ltd. – 2015 (39) S.T.R. 97 (Tri.-Ahmd.). The issue of the expenditure incurred by the appellant with reference to the branch office located abroad, which was involved in activities, which may fall under business auxiliary service was considered by the Tribunal. The Tribunal observed as below:-

“5.3 On the issue of demand of service tax of Rs. 11,56,32,589/- with respect to remittances made by the appellant to branch offices, both sides have relied upon the case law of M/s. British Airways v. CCE (Adj.) Delhi [2014-TIOL-979-CESTAT-MUM]. It is the case of the appellant that nearly Rs. 7 crore demand is with respect to salary of the employees of the appellant working in the foreign branch offices, treating the branch offices/establishments as service providers held by Revenue as a separate legal entities under the provisions contained in Section 66A(2) of the Finance Act, 1994. Senior Advocate appearing on behalf of the appellant strongly argued that in the light of provisions contained in Section 66A(2) of the Finance Act, 1994, the explanation-I has to be read only to clarify the place of services provided and not for the purpose of creating another service tax liability for an activity provided to self. For the remaining demand of service tax, it is the case of the appellant that this demand pertain to services availed abroad by the branch offices/ establishments as separate legal entities, on which VAT/GST of the relevant country was discharged by branch offices directly and receipt of these services is nothing to do with the appellant situated in India. It was fairly agreed by the learned Advocate that where local VAT/GST of a foreign country was not paid by the branch offices and billing was directly made by the foreign service providers to the appellant then in such cases service tax on reverse charge basis is required to be paid, which is being paid by the appellant even if the payment of such services availed and consumed in India were routed either through appellant‘s branch office or distributors.

5.4 Before giving our observations, it is relevant to glance through the provisions of Section 66A(1) of the Finance Act, 1994 reproduced below :-

“66A. Charge of service tax on services received from outside India. –

(1) Where any service specified in clause (105) of section 65 is,

(a) 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

(b) received by a person (hereinafter referred to as the recipient) who has his place of business, fixed establishment, permanent address or usual place of residence, in India, such service shall, for the purposes of this section, be taxable service, and such taxable service shall be treated as if the recipient had himself provided the service in India, and accordingly all the provisions of this Chapter shall apply :

Provided that where the recipient of the service is an individual and such service received by him is otherwise than for the purpose of use in any business or commerce, the provisions of this sub-section shall not apply:

Provided further that where the provider of the service has his business establishment both in that country and elsewhere, the country, where the establishment of the provider of service directly concerned with the provision of service is located, shall be treated as the country from which the service is provided or to be provided.

(2) Where a person is carrying on a business through a permanent establishment in India and through another permanent establishment in a country other than India, such permanent establishments shall be treated as separate persons for the purposes of this section.

Explanation 1. – A person carrying on a business through a branch or agency in any country shall be treated as having a business establishment in that country

Explanation 2. – Usual place of residence, in relation to a body corporate, means the place where it is incorporated or otherwise legally constituted.”

5.5 Section 66A (1) above is talking of service provider and service recipient as persons‘ which has to mean as different business persons. Section 66A(2) and its Explanation I only make a clarification and to fix service tax liability on recipient of services under reverse charge mechanism that both the permanent establishments in India and abroad of a business person are to be treated as separate persons. The above clarification/distinction made in Section 66A in our opinion is only for making an identification to determine whether a service is provided and consumed in India or abroad. It is an accepted legal position that one can not provide service to one‘s own self. If the permanent establishment‘ of the appellant abroad is treated as a service provider to its own head office in India then it will amount to charging service tax for an activity provided to one‘s own self. Similarly placed branches of the appellant undertaking similar activities in India will not be held so. Therefore, a comprehensive reading of Section 66A of the Finance Act, 1994, a permanent establishment situated abroad as a separate person‘, will be understood to have been prescribed only to determine the provision of service whether in India or out of India. Theoretically it could be possible that a person carrying business through a permanent establishment abroad may like to pay lower rate of local VAT/GST abroad to avoid service tax payment in India by showing the services to have been availed abroad. However, there is no likelihood of such avoidance in case of an assessee who is eligible to Cenvat credit in India for the service tax payable in India for which the assessee is entitled to Cenvat credit. It is also not the case of the of the Revenue that appellant is not capable of utilising Cenvat credit admissible as they have paid more than Rs. 12,000 crores as taxes during the periods 2007-2008 to 2011- 2012.”

7. The matter came up before the Tribunal again in the case of Milind Kulkarni – 2016 (44) STR 71 (Tri.-Mum.). The Tribunal after examining the earlier decision observed as below:-

“19.The appellant-assessee has established branches for furthering its commercial objectives. The benefit of assigned activities of the branch will, undoubtedly, accrue to the appellant. There is no dispute that it is the appellant-assessee who enters into contractual agreements with overseas customers for supply of information technology services‘ which have off-shore‘ components rendered directly to the overseas entity by the appellant-assessee. On-site‘ activity is undertaken by deputing employees working at the site of the customer. These employees are, without doubt, on the rolls of the appellant-assessee which, save for the specific and limited role of Section 66A(2), encompasses the branches within its corporate structure. As Section 66A(2) is limited to being a charging section in a specific context, it is not elastic enough to govern the corporate intercourse and commercial indivisibility of a headquarters and its branches. Therefore, any service rendered to the other contracting party by branch as a branch of the service provider would not be within the scope of Section 66A. Merely because there is a branch and that branch has, in some way, contributed to the activities of the appellant-assessee in discharging its contractual obligations, the definition of business auxiliary service‘ in Section 65(19) of Finance Act, 1994 may not apply. That is where the impugned order has erred in not reading Section 65(105) along with Section 66A and Rules framed for the purpose of charging tax on services received from abroad. Unless both are applied together, the jurisdiction to tax would be in question.

……………………………………………

……………………………………………

23.The catena of judgments cited for both sides, viz., British Airways v. Commissioner of Central Excise (Adjn) [2014-TIOL-979-CESTAT-Del = 2014 (36) S.T.R. 598 (Tri.-Del.)], Torrent Pharmaceuticals Ltd. v. Commissioner of Service Tax [2015 (39) S.T.R. 97 (Tri.-Ahmd.)] and Infosys Ltd. v. Commissioner of Service Tax [2014-TIOL-409-CESTAT-Bang = 2015 (37) S.T.R. 862 (Tri.-Bang.)] does support the proposition that a service is taxable under Section 66A of Finance Act, 1994 only when such service is rendered in India. The question that arises then in the context of the present dispute is whether the branch renders a service is rendered in India within the meaning of the above statutory provisions. A forced disaggregation merely for the purpose of tax when similar domestic structures are not taxed and when commercial soundness calls for establishment of branches would be clearly inequitable.

24. Hence, the legislative intent of this legal fiction may have to be ascertained. In doing so, the goals of the appellant as an exporter cannot be far from our mind. 25.Section 66A requires taxing of taxable services rendered by an overseas branch to its head office and the two sets of Rules limit tax demand only to the extent that these services are received in India in relation to business or commerce. A plain reading would make it apparent that the services referred to must be for pursuit of business or commerce in India. The two sets of Rules provide for availment of Cenvat credit of the tax paid by the Indian entity on reverse charge basis.‘ As an exporter, the Indian entity is entitled to claim refund of taxes lying unutilized in Cenvat credit account. There is no dispute that the activities of the branch are in connection with the export activity of the appellant-assessee. That the legislature would prescribe the collection of a tax merely for the purpose of refunding it subsequently does not pass the test of reason. More so, as there is no inference of any monitorial aspect in undertaking such an exercise. An exporter who operates through branches is clearly not the target of the legal fiction of branches being distinct from head office. The proposition that the intent of Section 66A in taxing the activity rendered by an overseas branch to its headquarters in India is limited to the local commercial or business activities of the head office is thereby confirmed. Consequently, mere existence as a branch for the overall promotion of the objectives of the primary establishment in India which is essentially an exporter of services does not render the transfer of financial resources to the branch taxable under Section 66A.

8. The ratio of the above decision and also the close reading of the proviso to Section 66A alongwith explanation therein is make it clear that the legal fiction of considering a branch of an assessee as a separate establishment is not to tax a service rendered to its head office. Further, here there is no such service also has been identified with supporting evidence.’

in the first of the two decisions setting aside the demand in their own appeal for the period prior to July 2012.

6. In the other decision of the Tribunal allowing their appeal against demand for one of the periods after the ‘negative list’ regime was enacted, it was held that

‘10. We note that the identical issue in respect of the appellant for the period prior to 01.07.2012 was considered and decided by the Tribunal in the Final Order No. 50314- 50315/2018 dated 12.01.2018. On a perusal of the said order, we find that the Tribunal has considered the issue with reference to the provisions of Section 66A (2) read with the Explanation I, which was on the statute book prior to 01.07.2012. The Tribunal placed reliance on the decision of the Tribunal in the case of Torrent Pharmaceuticals Ltd. vs. Commr. – 2015 (39) STR 97 (Tri.-Ahamd.) and came to the following conclusion:-

“5.5 Section 66A (1) above is talking of service provider and service recipient as “persons‟ which has to mean as different business persons. Section 66A(2) and its Explanation I only make a clarification and to fix service tax liability on recipient of services under reverse charge mechanism that both the permanent establishments in India and abroad of a business person are to be treated as separate persons. The above clarification/distinction made in Section 66A in our opinion is only for making an identification to determine whether a service is provided and consumed in India or abroad. It is an accepted legal position that one can not provide service to one’s own self. If the “permanent establishment‟ of the appellant abroad is treated as a service provider to its own head office in India then it will amount to charging service tax for an activity provided to one’s own self. Similarly placed branches of the appellant undertaking similar activities in India will not be held so. Therefore, a comprehensive reading of Section 66A of the Finance Act, 1994, a permanent establishment situated abroad as a “separate person‟, will be understood to have been prescribed only to determine the provision of service whether in India or out of India. Theoretically it could be possible that a person carrying business through a permanent establishment abroad may like to pay lower rate of local VAT/GST abroad to avoid service tax payment in India by showing the services to have been availed abroad.”

By referring to the above decision, the Tribunal came to the following conclusion:-

“8. The ratio of the above decision and also the close reading of the proviso to Section 66 A alongwith explanation therein is make it clear that the legal fiction of considering a branch of an assessee as a separate establishment is not to tax a service rendered to its head office. Further, here there is no such service also has been identified with supporting evidence. 9. We find that the ratio adopted by the Tribunal in examining the application of the said proviso is appropriate to the facts of the present case and accordingly, we hold that the tax liability under BAS cannot be sustained. We note here that the whole expenses now sought to be taxed are only with reference to setting up, running and also expenses of that branch incurred by the appellant and not relating to any expenditure in their branches with reference to BAS.”’

7. In the present dispute too, it is the admitted flow of funds for maintenance and upkeep of the branch offices that has been presumed to be the quid pro quo for rendering of ‘taxable service’ by the branch to the principal office. That the remittances were made for meeting the establishment costs at the location of the branches is not disputed.

8. In Milind Kulkarni, the Tribunal had been called upon to adjudge the legality of subjecting remittances made by the principal office to tax as ‘consideration’ for procurement of ‘business auxiliary service’ from their overseas branches for the period upto June 2012 and for procurement of ‘taxable service’ thereafter. Elaborating upon the scheme for taxing of services procured from abroad in Finance Act, 1994 read with the relevant Rules, it was held by the Tribunal that the deeming provision in a statute is a temporary suspension of conventional wisdom and existing legislative formulation of a concept or situation for a specified purpose and that the graft so incorporated is intended to be applied in its entirety and within the intended context. It, then, went on to enunciate the purpose of deeming demutualization as a contrivance to assure that structuring of such dependent establishments would not provide an avenue for escapement, either overtly or covertly, from the enforcement of the levy on the ‘taxable event’; concomitantly, the deemed demutualization does not demonstrate legislative intent to tax transactions that are normal to such dependent existence.

9. It was, therefore concluded that

‘24. Hence, the legislative intent of this legal fiction may have to be ascertained. In doing so, the goals of the appellant as an exporter cannot be far from our mind.

25. Section 66A requires taxing of taxable services rendered by an overseas branch to its head office and the two sets of Rules limit tax demand only to the extent that these services are received in India in relation to business or commerce. A plain reading would make it apparent that the services referred to must be for pursuit of business or commerce in India. The two sets of Rules provide for availment of Cenvat credit of the tax paid by the Indian entity on ‘reverse charge basis.’ As an exporter, the Indian entity is entitled to claim refund of taxes lying unutilized in Cenvat credit account. There is no dispute that the activities of the branch are in connection with the export activity of the appellant-assessee. That the legislature would prescribe the collection of a tax merely for the purpose of refunding it subsequently does not pass the test of reason. More so, as there is no inference of any monitorial aspect in undertaking such an exercise. An exporter who operates through branches is clearly not the target of the legal fiction of branches being distinct from head office. The proposition that the intent of Section 66A in taxing the activity rendered by an overseas branch to its headquarters in India is limited to the local commercial or business activities of the head office is thereby confirmed. Consequently, mere existence as a branch for the overall promotion of the objectives of the primary establishment in India which is essentially an exporter of services does not render the transfer of financial resources to the branch taxable under Section 66A.

26. The legal fiction of service rendered by overseas branch to its primary headquarters would appear to be intended to prevent escapement from tax by resort to branches specifically to take advantage of the principle of mutuality. When a service to be rendered in India by the primary establishment is deliberately routed through an overseas branch or when a service that would otherwise be contracted from an overseas entity is, instead, sourced through an overseas branch, this legal fiction will come into play. The transaction of the appellant-assessee and the branches which is under dispute before us being related to exports is unambiguously not intended to be taxed as it has nothing to do with business or commerce in India.

27. We do not need to examine whether the flow of funds from the head office to the branch is consideration or reimbursement as the test of services having been received in India fails. Nevertheless, we do so. A branch, by its very nature, cannot survive without resources assigned by the head office. The business of the appellant-assessee is such that credibility in the eyes of its overseas clients lies in the name and style of the appellant-assessee. It cannot be substituted by any other entity. The activity of the head office and branch are thus inextricably enmeshed. Its employees are the employees of the organization itself. There is no independent existence of the overseas branch as a business. The economic survival of the branch is entirely dependent on finances provided by the head office. Its mortality is entirely contingent upon the will and pleasure of the head office. The transfer of funds – by gross outflow or by netted inflow – is, therefore, nothing but reimbursements and taxing of such reimbursement would amount to taxing of transfer of funds which is not contemplated by Finance Act, 1994 whether before 2012 or after.’

10. With the transition to the ‘negative list’ regime, the substance of the transformation is reflected in the combination of section 65B, section 66B, section 66C, section 66D and section 66E of Finance Act, 1994 with the insertions having been crafted to accommodate the broadened and general description of ‘taxable services’, as defined in 65B(51) of Finance Act, 1944.

Documentation of the circumstances surrounding this paradigm shift does not offer any scope to infer that the concept which birthed the levy of services provided within the country, as well as those brought into the country, was intended to be re-shaped beyond the significant departure from the delineated description of each of the enumerated services hitherto existing.

10. Central to the revised schema is

SECTION 66B. Charge of service tax on and after Finance Act, 2012.

There shall be levied a tax (hereinafter referred to as the service tax) at the rate of fourteen percent on the value of all services, other than those services specified in the negative list, provided or agreed to be provided in the taxable territory by one person to another and collected in such manner as may be prescribed.’

with ‘provided or agreed to be provided in the taxable territory’ as the frame of event to be taxed. The mechanism for determination of any ‘service’ to have been rendered within the jurisdiction of such levy is established under the authority of

SECTION 66C. Determination of place of provision of service.

(1) The Central Government may, having regard to the nature and description of various services, by rules made in this regard, determine the place where such services are provided or deemed to have been provided or agreed to be provided or deemed to have been agreed to be provided.

(2) Any rule made under sub-section (1) shall not be invalid merely on the ground that either the service provider or the service receiver or both are located at a place being outside the taxable territory.’

Neither of these provisions makes passing reference to ‘consideration’ which finds a place in section 67 of Finance Act, 1994 and, for elaborating of the taxable event in section 66B of Finance Act, 1994 and of ‘taxable service’ wherever occurring, in

‘(44) “service” means any activity carried out by a person for another for consideration, and includes a declared service, but shall not include –

………………….’

of section 65B of Finance Act, 1944. On perusal of Place of Provision of Service Rules, 2012 that, by emphasis or by deeming so under the authority of section 66C of Finance Act, 1994, maps the boundary of ‘services provided or agreed to be provided in taxable territory’, it is seen that rule 4 to rule 6 and rule 9 to rule 12 address specific situations of deeming that do not find fitment within the default in rule 3; rule 7 is a determinative weightage for certain circumstances and rule 8 intends distribution of domestic jurisdiction. None of these are relevant to the present dispute save and except

‘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 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.’

which, with reference to

‘(i) “location of service receiver” means:-

(a) where the recipient of service has obtained a single registration, whether centralized or otherwise, the premises for which such registration has been obtained;

(b) where the recipient of service is not covered under sub-clause (a):

(i) the location of his business establishment; or

(ii) where services are used at a place other than the business establishment, that is to say, a fixed establishment elsewhere, the location of such establishment; or

(iii) where services are used at more than one establishment, whether business or fixed, the establishment most directly concerned with the use of the service; and

(iv) in the absence of such places, the usual place of residence of the recipient of service.

Explanation:-. For the purposes of clauses (h) and (i), “usual place of residence” in case of a body corporate means the place where it is incorporated or otherwise legally constituted….. ’

in rule 2 of Place of Provision of Service Rules, 2012 may well bring the locus back to demutualised relationship between the establishment in India and its branches abroad in much the same as Explanation 1 in section 66A did. And just as the determination of rendering of ‘taxable service’ in accordance with Taxation of Services (Provided from Outside India and Received in India) Rules, 2006 was essential for validation of any levy on ‘consideration’ remitted by principal office before July 2012, the Rules above, along with the parent provision in Finance Act, 1994 and the charging provision are applicable only to ‘services’, conforming to the description elaborated in section 65B(44) of Finance Act, 1994 therein, without exception after June 2012. There is no such ascertainment or finding in the impugned order.

11. Consequently, the conclusion in Milind Kulkarni, that was relied upon in Kusum Healthcare Ltd to set aside the demand after introduction of ‘negative list’ regime is similarly applicable to the dispute now impugned before us.

12. In these circumstances, the impugned order, being contrary to law, is liable to be set aside. We do so to allow the appeal.

(Order pronounced in the open court on 01/10/2021)

Notes:-

1. 2018 (2) TMI 1408-CESTAT-NEW DELHI

2. 2018 (7) TMI 919 CESTAT NEW DELHI

3. 2015 (39) STR 97 (Tri-Ahmd)

4. 2016 (44) STR 71 (Tri-Mum)

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