Service Tax Payable on SIM Card Activation Charges

Issue involved in this case is whether the value of sim cards sold by the appellant herein to their mobile subscribers is to be included in taxable service under Section 65(105)(zzzx) of the Finance Act, 1994 or otherwise.

The appellant were selling the sim cards to their franchisee and was paying sales tax to the State and activating the sim cards in the hands of subscribers at a valuable consideration and paying sales tax on the activation charges. They did not discharge the service tax liability on the gross value of the am

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