TMI Blog2017 (12) TMI 18X X X X Extracts X X X X X X X X Extracts X X X X ..... agent of the Reserve Bank of India, while selling such Government bonds - similar issue decided in the case of Enam Securities Pvt. Ltd. Vs Commissioner of Service Tax, Mumbai [2014 (11) TMI 585 - CESTAT MUMBAI], where it was held that the lending or borrowing of money by the Government is a sovereign function and on such functions there cannot be any tax liability whether by way of direct tax or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he original authority confirmed demand, interest as well as imposed penalty. In appeal, the Commissioner (Appeals) upheld the same. Hence, this appeal. 2. On behalf of the appellants, the learned consultant Shri Archit Agarwal submitted that the issue whether liability to pay service tax on the brokerage received from the Reserve Bank of India was settled by various judgments as in the case o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he above decisions. 3. Heard both sides and perused the records. 4. The issue is whether the appellants is liable to pay service tax on the brokerage received for the sale of Government bonds. It is not disputed that the appellants have been acting as an agent of the Reserve Bank of India, while selling such Government bonds. The said issue has been discussed in the case of Canara Bank, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d a brokerage for sale of the security. From the Circular dated 10-8-2010 issued by the C.B.E. C., it is clear that there is no Service Tax liability on underwriting fee or underwriting commission received by the primary dealers for dealing in Government securities; the same logic would apply in respect of brokerage also. Further, this Tribunal in the case of Canara Bank and Union Bank of India ..... X X X X Extracts X X X X X X X X Extracts X X X X
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