Stocks

25 November 2012

Penalty waived of as the assessee was under bona-fide belief that transaction wasn't a service

HIGH COURT OF GUJARAT
Commissioner
v.
Welspun Gujarat Sthal Rohren Ltd.


In the instant case, the assessee had imported certain drawings, designs. It classified them as goods and claimed exemption from customs duty. The Bill of Entry for such import was also finalized by custom authorities. Subsequently, the Department alleged that it was import of 'Intellectual Property Services' and accordingly demanded service tax along with interest and penalty.

On appeal, the High Court deleted penalty on basis of following findings of the Tribunal:
  • The assessee had paid the entire amount of service tax liability along with interest prior to issuance of the show cause notice and had not disputed the liability to pay service tax and interest;
  • The assessee had a bona fide belief that it was liable to pay customs duty on the drawings and designs imported by it as the same were goods;
  • Under the circumstances, no mala fide intent could be attributed to it in not discharging the service tax liability under the category of "Intellectual Property Rights Services"; and
  • The assessee had shown a reasonable cause for its failure to discharge service tax liability and was, therefore, entitled to relief under section 80.

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