Section 66A of Finance Act 1994 provides for payment of service tax by recipient of services in case the provider of services is from outside the country and he has no permanent establishment in the country. There was enormous debate about first the constitutional validity of this and also the date of enactment of this Section.
SERVICE TAX INSTRUCTION [F. NO. 276/8/2009-CX-8A], DATED 26-9-2011
Which states that the date of enactment of 66A will be 18.4.2006 and not 1.1.2005 as earlier contested vide
F No. 275/7/2010-CX-8A, dated 30-6-2010
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