RIL must pay service tax for services by Aker Malaysia under RCM for project and production stages.

Liability of service tax - RCM - The contract envisages services required to be provided to RIL, both at the project stage at which stage a support base was required to be set up as well as an ongoing basis when the oil and gas production was to commence. The reference to ‘support base‘ is to a repair yard where tools, spares, parts and testing equipments have to be kept and maintained. It is not in reference to a ‘project office‘ or any ‘fixed establishment‘. It would not be appropriate to read the word ‘established‘ as ‘establishment‘ - the inevitable conclusion that emerges from the above discussion is that RIL, as the service recipient, was required to discharge service tax liability on a reverse charge mechanism on the services provided by Aker Malaysia to RIL - AT .....

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