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2011 (9) TMI 102 - AT - Service TaxMoney Changers - Money Transfer services from persons located in one country to persons located in any country - PML argues that it is providing services to Western Union situated abroad with whom PML is having a contract for providing services and PML gets its remuneration from Western Union. Further the ultimate beneficiary of the service is the person situated abroad who approaches the office of Western Union abroad and who pays for the services. So this is a case of Export of Services as laid down in Export of Services Rules, 2005. - The Revenue contests that the activity of making payment to the recipient in India is the only service which PML is rendering and this service is rendered in India. The receiver of its service is the person receiving the remittance in India. The Revenue argues that no part of the service done by PML is exported. Two member bench of the CESTAT have different opinions and gave detailed and elaborated reasons to justify their stand regarding classification, export of services and applicability of expended period of limitation. Difference of opinion - Matter referred to larger bench.
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