𝗖𝗘𝗦𝗧𝗔𝗧 𝗖𝗵𝗲𝗻𝗻𝗮𝗶 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 𝗳𝗼𝗿 𝗩𝗲𝘀𝘀𝗲𝗹 𝗖𝗵𝗮𝗿𝘁𝗲𝗿𝘀 𝗮𝗻𝗱 𝗦𝗲𝗰𝘂𝗿𝗶𝘁𝘆 𝗗𝗲𝗽𝗼𝘀𝗶𝘁𝘀 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗿𝘂𝗹𝗲𝗱: "Providing vessels to a group company for export is not for transfer of right to use the vessels; therefore, no service tax is leviable under 'supply of tangible goods for use.'"

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: M/s. Core Minerals 𝗜𝘀𝘀𝘂𝗲: M/s. Core Minerals, contracted to transport cobblestone via voyage charter and provided vessels on a time charter to a group company. A show cause notice demanded service tax for "Supply of Tangible Goods Service" for 2008-10 and on a property rental security deposit, including interest and penalties.

⚖️ 𝗝𝘂𝗱𝗴𝗺𝗲𝗻𝘁: The Tribunal ruled that the voyage charter did not transfer the right to use the vessel, exempting it from service tax under "supply of tangible goods for use." The time charter lacked grounds for tax demands or penalties, and the refundable security deposit was non-taxable. The appeal was allowed.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: M/s. Core Minerals vs. The Commissioner of Service Tax 𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 𝗔𝗽𝗽𝗲𝗮𝗹 𝗡𝗼. 42451 of 2013 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 15 June 2023 📜 This ruling confirms that vessel charters without a transfer of use rights and refundable security deposits for rentals are not subject to service tax.