𝗖𝗘𝗦𝗧𝗔𝗧 𝗗𝗲𝗹𝗵𝗶 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 𝗟𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗼𝗳 𝗪𝗮𝗿𝗲𝗵𝗼𝘂𝘀𝗶𝗻𝗴 𝗜𝗻𝗰𝗼𝗺𝗲 𝗮𝗻𝗱 𝗕𝘂𝘀𝗶𝗻𝗲𝘀𝘀 𝗦𝘂𝗽𝗽𝗼𝗿𝘁 𝗦𝗲𝗿𝘃𝗶𝗰𝗲𝘀 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗿𝘂𝗹𝗲𝗱: "In a revenue-sharing arrangement within a joint venture for warehousing, neither party qualifies as a service provider or recipient, and therefore, service tax is not applicable."

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: M/s. Shree Shubham Logistics Ltd. in collaboration with Rajasthan State Warehousing Corporation 𝗜𝘀𝘀𝘂𝗲: Shree Shubham Logistics faced service tax demands on warehousing income under "business support" and "rental income"; Rajasthan State Warehousing faced similar demands for "intellectual property" and "business support services."

⚖️ 𝗝𝘂𝗱𝗴𝗺𝗲𝗻𝘁: The Tribunal held that Shree Shubham Logistics and Rajasthan State Warehousing Corporation's revenue-sharing agreement was a joint venture, not a service provider-recipient relationship, thus exempting it from service tax. This decision aligned with prior rulings and confirmed that warehousing agricultural produce remained non-taxable under the negative list.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: M/s. Shree Shubham Logistics Ltd. & Rajasthan State Warehousing Corp. vs. Commissioner of Central Excise, Jodhpur & Jaipur 𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 𝗔𝗽𝗽𝗲𝗮𝗹 𝗡𝗼. 51136 of 2017 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 11 August 2023 📜 The ruling affirms that revenue-sharing agreements in joint ventures for warehousing activities are not subject to service tax in the absence of a distinct service provider-recipient relationship.