Chariot World Tours Limited Vs Commissioner of Service Tax (CESTAT Bangalore)
The CESTAT Bangalore, in Final Order Nos. 20488-20489/2026 dated 13 April 2026, held that outbound international tour packages provided by an Indian tour operator to Indian tourists during April 2010 to March 2012 were liable to service tax under the category of “Tour Operator Service” under Section 65(105)(n) of the Finance Act, 1994. The Tribunal noted that the Larger Bench in Cox & Kings had held that, for the period prior to the negative list regime, where both the service provider and service recipient were in India, the services were taxable and determination of “taxable territory” was not required. Applying that ruling, the Tribunal confirmed the service tax demand with interest for the normal period of limitation. It also observed that the dispute involved interpretation of law and conflicting judicial views which had been referred to a Larger Bench, and therefore suppression of facts could not be alleged for invoking the extended period of limitation. Accordingly, the impugned orders were modified by restricting the demand to the normal period of limitation and setting aside the penalties, and the appeals were disposed of accordingly.
Facts:
M/s. Chariot World Tours Ltd. (“the Petitioner”) was engaged in providing taxable services under the category of “Tour Operator Service”. During the period April 2010 to March 2012, it organized and conducted international package tours for Indian tourists but did not discharge service tax on such outbound tour packages.
