Hi,

B ltd cannot utilise the 12.36, if B ltd has not made the payment of Rs.
112.36. Payment is very important factor in case of Service tax set off/
credit in terms of utilization.

Thanks & Regards,
Kiran Takke

On Wed, Nov 5, 2008 at 1:03 PM, K.Sankarasubramanian (Finance/TVS-E) <
[EMAIL PROTECTED]> wrote:

>   *A Ltd and B Ltd are associated enterprises as referred in Service Tax
> law*
>
> * *
>
> *A Ltd raised an Invoice on B Ltd for Rs 112.36 on 10.10.2008 (Basic = Rs
> 100 and Service tax/cess = Rs 12.36)*
>
> * *
>
> *Payment for the Invoice was not received till 31.10.2008*
>
> * *
>
> *So A Ltd included the Invoice value in the taxable turnover for Oct 2008
> and paid the Service Tax to the Govt on 05.11.2008*
>
> * *
>
> *B Ltd in turn also accounted the Invoice in Oct 2008 in their books and
> utilised the Service Tax Input Tax credit of Rs 12.36 in Oct 2008 on this as
> the transaction is between associated enterprises*
>
> * *
>
> *Is the action of B Ltd correct or not? Relevant statutory provisions
> below*
>
> * *
>
> *Pl give your views with case law or statutory references*
>
> * *
>
> *Thanks*
>
> * *
>
> *KSS**/5.11.2008*
>
> * *
>
> *Sec 67(1)(i) :: Service tax is chargeable on any taxable service with
> reference to the gross amount charged by the service provider for such
> service provided or to be provided by him*
>
> * *
>
> *Sec 67(4)(c) :: "gross amount charged" includes payment by cheque, credit
> card, deduction from account and any form of payment by issue of credit
> notes or debit notes and 'book adjustment, and any amount credited or
> debited, as the case may be, to any account, whether called "Suspense
> account" or by any other name, in the books of account of a person liable to
> pay service tax, where the transaction of taxable service is with any
> associated enterprise. [ Inserted vide Finance Bill 2008, w.e.f. 16th May,
> 2008 ]*
>
> * *
>
> *Sec 65(7b) :: "associated enterprise" has the meaning assigned to it in
> section 92A of the Income tax Act, 1961; [Inserted vide Finance Bill 2008
> w.e.f. 16th May, 2008*
>
> * *
>
>    *K Sankarasubramanian *
>
> *Taking IT to the heart of India*
>
> *Senior Manager - Finance*
> *TVS Electronics Limited
> *DP,34 South Phase,
> Industrial Estate, Guindy,
> Chennai 600 032. India.
>
>  Tel : +91-44-22321166
> Fax : +91-44-22327577
> Mob : +91-98400 93176
> Mail : [EMAIL PROTECTED]
> Web : www.tvs-e.in
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