Draft Circular - Clarification on technical issues relating to scope and classification of taxable services, levy of service tax and valuation of taxable services – reg - Service Tax - F.No.354/28/2007-TRU

Clarification on technical issues relating to scope and classification of taxable services, levy of service tax and valuation of taxable services - reg DRAFT CIRCULAR Circular No. / /2007-ST New Delhi, dated - - July, 2007 F.No.354/28/2007-TRU Government of India Ministry of Finance Department of Revenue Tax Research Unit Sub: Clarification on technical issues relating to scope and classification of taxable services, levy of service tax and valuation of taxable services - reg. **** Service Tax was introduced in the year 1994 with three taxable services. At present, one hundred services are specified as taxable services. Since the introduction of service tax, number of clarifications in the form of circulars/instructions/letters has been issued by the Central Board of Excise Customs (CBEC), Director General (Service Tax) and field formations. 2.Government decided to undertake a comprehensive review of all the clarifications issued since the introduction of service tax on matters relating to service tax in various forms by different authorities keeping in view the changes that had taken place in the statutory provisions, the judicial pronouncements and other relevant factors and appointed a Committee under Shri T.R.Rustagi, former Chief Commissioner of Customs Central Excise and Director General of Inspection to undertake the review of clarifications. 3. Comments, views and suggestions were also sought from the trade and industry associations, departmental officers and interested persons. 4. Shri T.R.Rustagi submitted his report to the Government and suggested to withdraw all the clarifications and codify the clarifications into two circulars - one relating to technical issues and the other relating to procedural issues. The report of Shri T.R.Rustagi has been placed on the CBEC web site for comments and suggestions. 5. Taking into consideration the report submitted by Shri T.R.Rustagi, views and suggestions received from the trade and industry associations, departmental officers and other stakeholders, it is proposed to codify and issue a comprehensive circular on technical issues. A separate circular will be issued for procedural issues. 6. This circular supersedes all circulars, clarifications and communications issued from time to time by the CBEC, DG (Service Tax) and various field formations on all technical issues including scope and classification of taxable services, valuation of taxable services, export of services, services received from outside India, scope of exemptions and all other matters on levy of service tax. With the issue of this circular, all the clarifications issued on technical issues relating to service tax stand withdrawn. 7. At the time of introduction of the Finance Bills and after enactment of respective Finance Acts, TRU issue letters explaining the scope of various provisions contained in the Finance Bills/Acts. Such letters explaining the provisions contained in the Finance Bill/Finance Act would be read in the relevant context. 8. Views stated in the circular reflect the interpretation of the law and the current practice of the department. This circular is not to be treated as part of law and does not override it.Relevant statutory provisions are to be referred. 9. REFERENCE CODING SYSTEM: In the circular, for ease of reference a coding system is followed. Views are indicated separately for each individual issue. For each issue, a corresponding reference code is given. Each taxable service is identified by a three-digit code. First three digits of the reference code relates to a specific taxable service. In addition, following three digit codes are also followed: 996 - Services provided from outside India and received in India. 997 - Export of Services 998 - Valuation of taxable services. 999 - Miscellaneous purposes. Three-digit code is followed by a dot and two digits. The two digits after the dot indicate number of the issue clarified under that particular taxable service. Digit codes are followed by a slash and thereafter the date of issue of the clarification is indicated. 10. List of three-digit codes and the corresponding subject is given in Annexure I. Reference Code Issue Comment (1) (2) (3) 002.01/01.07.07 Whether service tax is leviable on the amount collected as surcharge for delayed payment of telephone bills. An amount collected for delayed payment of a telephone bill is not to be treated as consideration charged for provision of telecom service and therefore, does not form part of the value of taxable service under section 67 read with Service Tax (Determination of Value) Rules, 2006. 004.01/01.07.07 Persons/agencies canvass advertisements for publishing, on commission basis. Such persons / agencies do not provide any other services like making, preparation, display or exhibition of advertisement. Whether merely canvassing advertisement for publishing on a commission basis by persons / agencies is classifiable as Advertising Agency service [section 65(105)(e)] or not. Merely canvassing advertisements for publishing, on commission basis, is not classifiable under the taxable service falling under section 65(105)(e). Such services are leviable to service tax under business auxiliary service [section 65(105)(zzb)]. 005.01/01.07.07 Some transporters undertake door- to-door transportation of goods or articles and they have made special arrangements for speedy transportation and timely delivery of such goods or articles. Such services are known as 'Express Cargo Service' with assurance of timely delivery. Whether such 'Express cargo service' is covered under courier agency service [section 65(105)(f)]. The nature of service provided by 'Express Cargo Service' provider falls within the scope and definition of the courier agency. Hence, the said service is leviable to service tax under courier agency service [section 65(105)(f)]. 005.02/01.07.07 "Angadia" undertakes delivery of documents, goods or articles received from a customer to another person for a consideration. Whether services provided by angadia is leviable to service tax under courier agency service [section 65(105)(f)]. Angadias are covered within the definition of 'courier agency' [section 65(33)]. Therefore, such services provided by angadia is leviable to service tax under courier agency service [section 65(105)(f)]. 006.01/01.07.07 Whether a self-employed professionally qualified engineer can be considered as 'consulting engineer' [section 65(31)] and service provided by such self-employed professionally qualified engineer to a client in relation to one or more discipline of engineering is leviable to service tax under consulting engineer service [section 65(105)(g)]. Consulting engineers include self-employed professionally qualified engineer, whether or not employing others for assistance. Services provided by such self-employed professionally qualified engineer to a client in relation to one or more discipline of engineering is leviable to service tax under consulting engineer service [section 65(105)(g)]. 010.01//01.07.07 Educational institutes such as IITs, IIMs charge a fee from prospective employers like corporate houses / MNCs, who come to the institutes for recruiting candidates through campus interviews. Whether services provided by such institutions in relation to recruitment of manpower are leviable to service tax under 'manpower recruitment or supply agency' service [section 65(105)(k)]. 'Manpower recruitment or supply agency' is defined as "any person engaged in providing any service, directly or indirectly, in any manner for recruitment or supply of manpower, temporarily or otherwise, to a client" [section65 (68)]. Educational institutes such as IITs, IIMs, fall within the definition of 'manpower recruitment or supply agency', and service tax is leviable on services provided by such institutions in relation to campus recruitment under section 65(105)(k). 012.01/01.07.07 "Mandap" is defined as any immovable property as defined in section 3 of the Transfer of Property Act, 1882 and includes any furniture, fixtures, light fittings and floor coverings therein let out for a consideration for organizing any official, social or business function. [section 65(66)] "Mandap keeper" is defined as a person who allows temporary occupation of a mandap for a consideration for organising any official, social or business function [section 65(67)]. Whether hotels / restaurants letting out their halls, rooms etc. for social, official or business functions fall within the definition of "mandap" and allowing temporary occupation of halls, rooms etc by such hotels / restaurants for organizing any official, social or business function is leviable to service tax under "mandap keeper service" [section 65(105)(m)]. Halls, rooms etc. let out by hotels / restaurants for a consideration for organising social, official or business functions are covered within the scope of "mandap" [section 65(66)], and such hotels and restaurants are covered within the scope of "mandap keeper" [section 65(67)]. Accordingly, service tax is leviable on services provided by hotels and restaurants in relation to letting out of halls, rooms, etc. for organizing any official, social or business function under mandap keeper service [section 65(105)(m)]. 012.02/01.07.07 Whether allowing temporary occupation of a hall for the purpose of holding dance, drama or music programme or competitions is leviable to service tax under Mandap Keeper Service. Dance, drama or music programme or competitions are social functions and allowing temporary occupation of a hall for a consideration for organizing such functions are leviable to service tax under Mandap Keeper Service [section 65(105)(m)]. 017.01/01.07.07 Whether services provided in relation to merger or acquisition is covered under management or business consultant service [section 65(105)(r)] Services provided in relation to merger, acquisition and other form of restructuring of business organization are covered within the scope of management or business consultant service [section 65(105)(r)]. 032.01/01.07.07 Whether Prasar Bharati Corporation (Doordarshan and All India Radio) are liable to pay service tax under Broadcasting Service [section 65(105) (zk)], Prior to 1.3.2003, Prasar Bharati Corporation did not pay service tax by virtue of erstwhile section 22 of the Prasar Bharati (Broadcasting Corporation of India) Act, 1990. However, the said section 22 was omitted vide section 163 of the Finance Act, 2002 with effect from 1.4.2003. In view of the above statutory changes, with effect from 1.4.2003 Prasar Bharati Corporation is liable to pay service tax for the broadcasting services provided like any other broadcasting agency or organization engaged in providing service in relation to broadcasting. 034.01/01.07.07 Moneychangers are persons authorized under section 7 of Foreign Exchange Management Act, 1973 to deal in foreign currency. Explanation given under Section 7 of the said Act states that 'dealing' means purchasing foreign currency in the form of notes, coins or traveller's cheques or selling foreign currency in the form of notes or coins. Whether services provided by a money changer in relation to dealing of foreign currency (buying or selling), at specified rates, without separately charging any amount as commission for such dealing, is leviable to service tax as foreign exchange broking under 'banking and other financial services' [section 65(105) (zm)]. Moneychangers are authorized by RBI to buy and sell foreign exchange at the prevalent market rates. Buying or selling of foreign exchange by such persons without separately charging any amount as commission or brokerage does not fall within the scope of foreign exchange broking and is not leviable to service tax under section 65(105)(zm). 034.02/01.07.07 'Asset management and all other forms of fund management' are leviable to service tax under 'banking and other financial service' [section 65(12)]. Whether the amount charged as 'entry and exit load' from the investor by a mutual fund is leviable to service tax as asset / fund management services under banking and other financial services [section 65(105)(zm)]. Entry load and exit load charged by a mutual fund are not for the purpose of management of assets. Thus, amount charged as "entry and exit load" are not to be treated as consideration received by Asset Management Company for asset management and hence not be leviable to service tax under banking and other financial service [section 65(105)(zm)]. 034.03/01.07.07 Whether depository services and Electronic Access to Securities Information (EASI) services provided by Central Depository Services (India) Ltd., (CDSL) is leviable to service tax under Banking and other Financial Services[section 65(105)(zm)]. Definition of "Banking and other Financial Services" specifically includes "provision and transfer of information and data processing [section 65(12)(a)(vii)]". Services provided by CDSL falls within the scope of "provision and transfer of information and data processing". These services are not in the nature of "on-line information and data base access or retrieval services". Therefore, the depository services provided by CDSL including Electronic Access to Securities Information (EASI) for a fee are leviable to service tax under Banking and other Financial Services. [section 65(105)(zm)] 035.01/01.07.07 Whether repair of ships during dry-docking by persons duly authorized by the Port is leviable to service tax under port service [section 65(105) (zn)]. Repair of ships in an Indian port, whether or not during dry-docking, by the port or by the person duly authorized by the port authorities is leviable to service tax under port service. 035.02/01.07.07 Management Committee of Paradeep Port was constituted as per the directions of Supreme Court of India. The Committee operates under the "Paradeep Port, Clearing, Forwarding and Handling Workers (Regulation of Employment) Scheme, 1994". Officers of the Paradeep Port Trust are associated with the Committee. The Committee is authorized by the Port Trust to provide a number of services within the port area for a consideration. Whether services provided by the Management Committee within the port area for a consideration is leviable to service tax under Port Service. As the Management Committee of Paradeep Port is authorized by the Port Trust to provide services within the port area at the prescribed rates, such services provided by the Committee are leviable to service tax under Port Service. [section 65(105) (zn)] 036.01/01.07.07 Authorized dealers of motor vehicles provide to customers free servicing of motor vehicles without charging any amount as service charge from the customers. The vehicle manufacturer promises such a facility to attract customers and reimburses the service charges to the authorised dealers, who provide to customers free servicing of motor vehicles. However, as per agreement, consideration for the service provider is not directly paid by the customer but by the vehicle manufacturer. Whether such 'free services' given to the customer free of cost by the authorized dealers (for which they are reimbursed by the vehicle manufacturers) are leviable to service tax under authorised service station service [section 65(105) (zo)]. In this case, service is provided by an authorised service station to a customer and the service provider receives the consideration for the services provided. Service tax is leviable on the amount received from the vehicle manufacturer for the purpose of servicing of vehicles. 036.02/01.07.07 Whether servicing/repair of heavy vehicles like trucks by authorized service station is leviable to service tax under section 65(105)(zo). Service tax is leviable on services provided by an authorised service station to a customer in relation to service, repair, reconditioning or restoration of motorcars, light motor vehicles or two-wheeled motor vehicles [section 65(105)(zo)]. Thus, servicing of heavy vehicles like trucks, not being one of the specified categories of motor vehicles, is not covered within the scope of the said taxable service. 036.03/01.07.07 Whether spare parts sold by a service station during the servicing of vehicles is liable to payment of service tax. Whether exemption can be claimed on the cost of consumables that get consumed during the course of providing service. Service tax is not leviable on sale of goods. Whether a given transaction between the service station and the customer is a sale or not, is to be determined taking into account the real nature and material facts of the transaction. When there is a sale, sales tax / VAT would have been paid. Any goods used in the course of providing service are to be treated as inputs for providing the service and accordingly, cost of such inputs should form integral part of the value of the taxable service. 041.01/01.07.07 Organizers of Trade Fairs and Exhibitions solicit participation from the trade and industry and provide space and other facilities, including furniture, cabins, security, electricity, etc., to display products and provision of services. Whether services provided by the organizers of trade fairs / exhibitions are covered within the scope of event management service [section 65(015)(zu)]. In such cases, the event, namely organizing trade fairs and exhibitions, is managed by the organizer himself and hence, being in the nature of self supply of service, this service is not leviable to service tax as 'Event Management' service. However organizers do provide service to an exhibitor and such service is leviable to service tax under "Business Exhibition Service [Section 65(105)(zzo)]. 047.01/01.07.07 Whether services provided in relation to handling / storage and warehousing of empty containers is leviable to service tax under storage and warehousing service [section 65(105)(zza)]. Empty containers are covered within the meaning of "goods" [section 65(50)]. Thus, services provided in relation to storage and warehousing of empty containers is leviable to service tax under storage and warehousing service [section 65(105)(zza)]. 048.01/01.07.07 Whether commission received by distributors for distribution of mutual fund units is liable to Service Tax under business auxiliary service. Distributors receive commission from mutual fund for providing services relating to purchase and sale of Mutual fund units. Services provided by such distributors are in the nature of commission agent and are, thus, leviable to service tax under business auxiliary service [section 65(105)(zzb)]. 076.01/01.07.07 "Club or association" is defined as any person or body of persons providing services, facilities or advantages, for a subscription or any other amount, to its members, but does not include such person or body of persons engaged in any activity having objectives which are of a charitable nature. Whether a club or association enjoying exemption under the provisions of Income Tax Act as a public charitable institution gets automatically excluded from levy of service tax under section 65(105)(zzze) read with section 65(25a) of the Finance Act, 1994. Exemption under the Income Tax Act on the ground of being a public charitable institution is of no consequence or relevance for service tax purposes. Levy of service tax is entirely governed by the provisions contained in the Finance Act, 1994 and the rules made there under. "Charity" is defined as "aid given to the poor, the suffering or the general community for religious, educational, economic, public safety, or medical purposes", and "charitable" is defined as "dedicated to a general public purpose, usually for the benefit of needy people who cannot pay for the benefits received" [Black's Law Dictionary]. Whether a club or association are engaged in activity having objectives, which are of a charitable nature, or not is to be determined purely on the basis of the circumstances and material factors. 086.01/01.07.07 An international journey commencing from an Indian airport involves stopover / transfer at intermediate airports outside India before reaching the destination (say Mumbai-Dubai-London-New York). Whether service tax would be leviable in such case on the value indicated in the ticket for the entire journey or only on that part of the value attributable to the first sector (Mumbai-Dubai) of the journey. Aim of the passenger is to travel from Mumbai to New York. Actual destination of the international journey is the criteria to decide the value of the service. (in this case, New York). Stopover / transfer at intermediate airports, being merely incidental and part of the main journey, is of no relevance or consequence for levy of service tax under section 65(105)(zzzo) read with section 66. Service tax in such cases is leviable on the total consideration of a single composite service relating to the entire journey. i.e., value indicated in the ticket for the entire journey. 086.02/01.07.07 An international journey (say Delhi-Mumbai-London) includes travel in a domestic sector (Delhi - Mumbai) as part of the international journey Whether service tax is leviable on the value of whole journey or after excluding the value attributable to the domestic sector from the total value of the ticket. In this case, the journey is a single composite journey. The aim of the passenger is to travel from India to outside India. Part of the travel in the domestic sector cannot be segregated from the single journey. service tax is, therefore, leviable on the total value of the ticket treating the domestic sector as integral part of international journey without excluding the value attributable, if any, to the domestic sector travel. 086.03/01.07.07 An international journey commences from an airport outside India and completed at an airport outside India but including a sector wherein the passenger disembarks and subsequently embarks at an Indian airport as part of international journey (say Sydney-Mumbai-Dubai-Singapore-Sydney). Whether service tax is leviable for Mumbai-Dubai sector only or on the total value of the ticket. In this case, the journey being a single one and the aim of the passenger is not to travel from India to outside India, service tax is not leviable under section 65(105)(zzzo). 086.04/01.07.07 Whether ticket issued outside India for an international journey commencing from India (say Delhi-London) is leviable to service tax. Service tax is payable by the service provider, namely aircraft operator, for the taxable service provided. Place of purchase/ issue of ticket is of no relevance or consequence to determine the levy of service tax under section 65(105)(zzzo) read with section 66. Service tax is leviable as long as the passenger embarks in India for international journey, in any class other than economy class. 999.01/01.07.07 Sovereign/public authorities perform functions assigned to them under the law in force, known as "statutory functions". For example, Regional Reference Standards Laboratories (RRSL) undertake verification, approval and calibration of weighing and measuring instruments; Regional Transport Officers (RTO) issue fitness certificate to motor vehicles; Directorate of Boilers inspects and issues certificates for boilers; or Explosive Department inspects and issues certificate for petroleum storage tank, LPG/CNG tank in terms of provisions of the relevant laws. Authorities providing such functions, required to be performed as per law, may collect specific amount or fee and the amount so collected is deposited into government account. Whether such activities of a sovereign / public authority, performed under a statute, can be considered as 'provision of service' for the purpose of levy of service tax and the amount or fee collected, if any, for such purposes can be treated as consideration for the services provided? Activities assigned to and performed by the sovereign / public authorities under the provisions of law, are statutory. The fee or amount collected as per the provisions of the relevant statute for performing such functions is in the nature of a compulsory levy and are deposited into the Government account. Such activities are purely in a public interest and are undertaken as a mandatory and statutory function. These are not to be treated as services provided for a consideration. Therefore, such activities assigned to and performed by a sovereign / public authority under the provisions of law, does not constitute provision of taxable service. Any amount / fee collected in such cases are not to be treated as consideration for the purpose of service tax levy. However, if a sovereign / public authority provides a service, which is not in the nature of statutory activity and the same is undertaken for a consideration (not a statutory fee), then in such cases, service tax would be leviable as long as the activity undertaken falls within the scope of a taxable service. 999.02/01.07.07 Department of Posts provides a number of services. What is the status of those services for the purpose of levy of service tax. Following services provided by Department of Posts are not leviable to service tax. Basic mail services known as postal services such as post card, inland letter, book post, registered post provided exclusively by the Department of Posts to meet the universal postal obligations. Transfer of money through money orders, operation of savings accounts, issue of postal orders, pension payments and other similar services which are of the nature of banking and other financial services. Department of Posts also provides a number of services used predominantly for business or commerce which are also provided by other commercial organizations. Services such as courier services (Speed Post) Insurance Services (Postal Life Insurance), Agency or intermediary services on commission basis (distribution of mutual funds, bonds, passport applications, collection of telephone and electricity bills) fall under the category of services where Department of Posts is in competition with other similar service providers. Such category of services are liable to service tax under appropriate taxable services. (G.G.Pai) Under Secretary (Tax Research Unit) ANNEXURE I Three digit Code Taxable Service / Others 001 Stock broker [Section (105)(a)] 002 Telecom Service [Section (105)(zzzx)] 003 General insurance [Section (105)(d)] 004 Advertising agency [Section (105)(e)] 005 Courier agency [Section (105)(f)] 006 Consulting engineer [Section (105)(g)] 007 Custom house agent [Section (105)(h)] 008 Steamer agent [Section (105)(i)] 009 Clearing and forwarding agent [Section (105)(j)] 010 Manpower recruitment agent [Section (105)(k)] 011 Air travel agent [Section (105)(l)] 012 Mandap keeper [Section (105)(m)] 013 Tour operator [Section (105)(n)] 014 Rent-a-cab scheme operator [Section (105)(o)] 015 Architect [Section (105)(p)] 016 Interior decorator [Section (105)(q)] 017 Management or Business consultant [Section (105)(r)] 018 Chartered accountant [Section (105)(s)] 019 Cost accountant [Section (105)(t)] 020 Company secretary [Section (105)(u)] 021 Real estate agent [Section (105)(v)] 022 Security agency [Section (105)(w)] 023 Credit rating agency [Section (105)(x)] 024 Market research agency [Section (105)(y)] 025 Underwriter [Section (105)(z)] 026 Scientific or technical consultancy [Section (105)(za)] 027 Photography [Section (105)(zb)] 028 Convention [Section (105)(zc)] 029 On-line information and database access or retrieval [Section (105)(zh)] 030 Video tape production [Section (105)(zi)] 031 Sound recording [Section (105)(zj)] 032 Broadcasting agency or organization [Section (105)(zk)] 033 Insurance auxiliary services concerning general insurance business [Section (105)(zl)] 034 Banking and other financial services [Section (105)(zm)] 035 Port [Section (105)(zn)] 036 Authorized service station [Section (105)(zo)] 037 Beauty treatment [Section (105)(zq)] 038 Cargo handling [Section (105)(zr)] 039 Cable operator [Section (105)(zs)] 040 Dry cleaning [Section (105)(zt)] 041 Event management [Section (105)(zu)] 042 Fashion designing [Section (105)(zv)] 043 Health club and fitness [Section (105)(zw)] 044 Life insurance in relation to risk cover [Section (105)(zx)] 045 Insurance auxiliary services concerning life insurance business [Section (105)(zy)] 046 Rail travel agent [Section (105)(zz)] 047 Storage and warehousing [Section (105)(zza)] 048 Business auxiliary service [Section (105)(zzb)] 049 Commercial coaching or training [Section (105)(zzc)] 050 Erection, commissioning or installation [Section (105)(zzd)] 051 Franchise [Section (105)(zze)] 052 Internet caf [Section (105)(zzf)] 053 Management, maintenance or repair [Section (105)(zzg)] 054 Technical testing and analysis [Section (105)(zzh)] 055 Technical inspection and certification [Section (105)(zzi)] 056 Foreign exchange broker [Section (105)(zzk)] 057 Other port [Section (105)(zzl)] 058 Airport [Section (105)(zzm)] 059 Transport of goods by aircraft [Section (105)(zzn)] 060 Business exhibition [Section (105)(zzo)] 061 Transport of goods by road [Section (105)(zzp)] 062 Commercial or industrial construction [Section (105)(zzq)] 063 Intellectual property [Section (105)(zzr)] 064 Opinion poll [Section (105)(zzs)] 065 Outdoor caterer [Section (105)(zzt)] 066 Programme producer [Section (105)(zzu)] 067 Survey and exploration of mineral [Section (105)(zzv)] 068 Pandal or shamiana [Section (105)(zzw)] 069 Travel agent [Section (105)(zzx)] 070 Forward contract [Section (105)(zzy)] 071 Transport of goods other than water through pipeline or other conduit [Section (105)(zzz)] 072 Site formation and clearance, excavation and earthmoving and demolition and such other activities [Section (105)(zzza)] 073 Dredging [Section (105)(zzzb)] 074 Survey and map-making [Section (105)(zzzc)] 075 Cleaning activity [Section (105)(zzzd)] 076 Club or association [Section (105)(zzze)] 077 Packaging activity [Section (105)(zzzf)] 078 Mailing list compilation and mailing [Section (105)(zzzg)] 079 Construction of complex [Section (105)(zzzh)] 080 Registrar to an issue [Section (105)(zzzi)] 081 Share transfer agent [Section (105)(zzzj)] 082 Automated teller machine operations, maintenance or management [Section (105)(zzzk)] 083 Recovery agent [Section (105)(zzzl)] 084 Sale of space or time for advertisement [Section (105)(zzzm)] 085 Sponsorship [Section (105)(zzzn)] 086 Transport of passenger embarking in India for international journey by air [Section (105)(zzzo)] 087 Transport of goods in containers by rail [Section (105)(zzzp)] 088 Support services of business or commerce [Section (105)(zzzq)] 089 Auctioneers [Section (105)(zzzr)] 090 Public relations [Section (105)(zzzs)] 091 Ship management [Section (105)(zzzt)] 092 Internet telephony [Section (105)(zzzu)] 093 Transport by cruise ship [Section (105)(zzzv)] 094 Credit card, debit card, charge card or other payment card [Section (105)(zzzw)] 095 Mining [Section (105)(zzzy)] 096 Renting of immovable property [Section (105)(zzzz )] 097 Services involved in the execution of works contract [Section (105)(zzzza)] 098 Development and supply of content [Section (105)(zzzzb)] 099 Asset management service by individuals [Section (105)(zzzzc)] 100 Design services [Section (105)(zzzzd)] 996 Services provided from outside India and received in India 997 Export of Services 998 Valuation of taxable services 999 Miscellaneous **** CBEC solicits views, comments and suggestions on the draft circulars, particularly suggestion for inclusion of any additional issues in the proposed circulars, from the trade and industry associations, departmental officers and others. The views, comments and suggestions may be sent so as to reach CBEC on or before 29 th June, 2007. Comments and suggestions on the draft circulars - (i) on technical issues may be sent to Shri Girdhar G. Pai, Under Secretary (TRU), CBEC, Room No.146-G, North Block, New Delhi. Fax No. 011-23093037. E-mail: [email protected] (ii) on the procedural issues may be sent to Shri G.D. Lohani, OSD (Service Tax), CBEC, North Block, New Delhi. Fax No. 011-23092275. E-mail: [email protected] / [email protected]