Critical Analysis on Reverse Charge Mechanism in

Service Tax
on 17 September 2014

Who can be person liable to pay Service Tax

Every person providing taxable service (service provider) shall pay tax @ prescribed
rate, to be collected in prescribed manner. [section 68(1)].
Service recipient is a person liable to pay service tax in certain cases [section 68
(2)] Defined in rule 2(1)(d) of Service Tax Rules, 1994 and 2(m) of POP Rules, 2012.
Person liable to pay service tax u/s 68 read with rule 2(1)(d) of ST
Rules,1994
Service provider
Specified service receivers [Rule 2(1)(d)(i)(A to G)]
Importer of service
Reverse Charge Mechanism in service tax is not a new concept. Under this
scheme, service tax is payable by service recipient instead of service provider.
Under this charge service receiver has to register himself under service tax.Further
service receiver cannot claim general exemption limit of 10 Lakh rupees. So he has
to pay even on few rupees of service received.
It will be Very harsh on service receiver end where he has received services
falls under reverse charge for only few hundred rupees but due to it he has to
register himself in service tax and have to file service tax return on prescribed
interval. Moreover under service tax act Nil return is also mandatory and every
registered person have to file half yearly return.
Now after applicability of new service tax regime, new services which is very
common like advocate, Hiring vehicle for passengers, has been added under
reverse charge.Few new services has been added with partial reverse charge from
01.07.2012. In case of these services both service receiver and provider has to pay
service tax in prescribed ratio.
Reverse Charge is not applicable on New services inserted from 01.07.2012 if it has
been provided before 01.07.2012, even if payment is made after 30.06.2012.
In case of Reverse charge mechanism Point of taxation is Date of Payment to
service provider. (Rule-7)

Reverse Charge (Tax Shift)

a. Generally, service tax is payable by person providing the service who actually
collect the tax and pays to government.
b. But Section 68(2) of Finance Act,1994 makes provision for reverse charge
i.e. making person receiving the service liable to pay tax.

c. Provision can be made that part of tax will be paid by service receiver
and part by service provider or entire by Service Receiver.
d. Provisions relating to reverse charge are contained in Notification No.
30/2012-ST dated 20-6-2012. See Appendix 2 for tax of the Notification and
amended from time to time.

Procedural part for Reverse Charge Mechanism

1. Update Service Tax Registration Certificate for Services covered under reverse
charge mechanism before payment or filling of service tax return under
reverse charge mechanism.(Service Recipient)
2. CENVAT CREDIT: In case of an input service where service tax is paid
on reverse charge by the recipient of the service, the CENVAT credit in respect of
such input service shall allowed on or after the day on which
- paymentis made on the value of input service and
- Service tax paid or payable as indicated in invoice referred in Rule 9.
3. Even if Service Provider is liable for payment of service tax in certain portion say
e.g.25%, 50% etc can avail Cenvat Credit on entire input w.r.t.334/1/2012.
4.Cenvat credit cannot be used to pay tax by service receiver. Service tax as to be
paid bycash only i.e. GAR-7 challan.
5. Once paid, Cenvat credit can be taken if otherwise it is his eligible input service
as perthe above mentioned Point 2.
6.Reverse charge with condition of non-availability of Cenvat: In some
services (e.g.GTA, renting or hire of motor vehicle designed to carry
passengers), the abatement issubject to condition of non-availment of Cenvat
credit by service provider (not by servicereceiver)
7. Payment of Service Tax by Service receiver only after making
payment to service provider: Now the service tax is payable on accrual basis
but in case of reverse chargeservice tax is payable only after payment is done to
service provider, subject to paymentdone within 6 months.
8. Payment of Service Tax: Payment of service tax under reverse charge
mechanismshall be in cash and cant be utilized Cenvat credit against service tax
liability in reversecharge mechanism.
9. Small Service Provider: No benefit of Basic exemption limit of Rs ten lacks is
availableas per the NN 6/2005, Except in case of legal service provided by
Advocate.

10. TDS Matter:

with my opinion TDS to be deducted on net billing amount
instead ofservice tax paid i.e. excluding service tax under reverse charge
mechanism.
11. What if Service Provider paid service tax instead of service receiver. In such
cases noneed to pay service tax again under reverse charge mechanism to
avoid the doubletaxation on single income. Some case laws a. Lilason Breweries
vs CCE, CCE Vs Om TeaCompany
12. Refund of CENVAT Credit: AS per Rule 5B of CCR 2004 Refund, A provider of
servicesis being unable to utilize the CENVAT credit on inputs and input services for
payment of service tax on such output services, shall be allowed refund for
unutilized service tax,subject to safeguard rules.
13. Billing by service provider
a. Service provider should charge only his part
receiver to payservice tax of his part by GAR 7 challan

of

service

tax

Service

b. Service receiver liable for only his part and not entire amount, even if service
providerdoes not charge his portion of service tax.
c. A statutory liability cannot be shifted by mutual agreement. If statutory liability
is ofservice receiver, he alone is liable.

Service Tax Provisions under Reverse Charge Mechanism (w.e.f

0`.07.2012)
1. Point of taxation under reverse charge mechanism is date of payment to
the service provider provided payment must happen within 6 months from the
date of invoice otherwise point of taxation will be date of invoice. Invoice needs
to be issued by the service provider within 30 days of completion of each
event/service. If invoice is not issued within the specified time, point of taxation will
be the date of completion of provision of service.
Provided that in case of associated enterprises, where the person providing
the service is located outside India, the point of taxation shall be the date of
debit in the books of account of the person receiving the service or date of
making the payment whichever is earlier.
For any service whose point of taxation has been determined and whole
liability affixed before 1.7.2012/7.8.2012, the new provisions will not apply. Merely
because payments are being made on or after 1.7.2012/7.8.2012 will not add any
additional liability on the service receiver in respect of such services.
2. Service tax under reverse charge is applicable even if service provider is exempt
from service tax up to the taxable value of 10 Lac. There is no threshold limit of
exemption for the service receiver under reverse charge mechanism.

3. Input credit of service tax paid by recipient under reverse charge mechanism can
be availed on the basis of tax payment challan. In case of Banks and NBFCs, Rule
6(3B) of CENVAT rules will also apply to input credit of service tax paid under
reverse charge mechanism.
4*. In the following cases, 100% service tax liability rests with the
service provider only if service provider is a corporate entity:i. Renting of motor vehicle.
ii. Manpower services & security Services
iii. Works contract
In the above cases, service recipient will pay nothing under reverse
charge mechanism.
5. It is the responsibility of service recipient to determine whether particular works
contract covered under 11(a) to 11(c) is leviable to VAT or not. Service recipient is
liable under reverse charge mechanism even if service provider does not charge
VAT/WCT in invoice if VAT/WCT is otherwise applicable.
6. Provisions relating to works contract are applicable even if material is purchased
from a separate person other than the person rendering services or under separate
agreement or under separate invoice.
7. Valuation of Works Contract covered under 11(a) to 11(c) = Gross amount
charged in invoice by service provider for labour and material used in execution
of works contract (excluding taxes) plus fair market value of goods supplied by
the service recipient used in execution of works contract (excluding taxes) less
amount charged by service recipient from service provider in respect of goods
supplied in relation to works contract.
If the service provider segregates the amount of labour and material in the
invoice, service provider (non-company) will charge service tax @ 6.18% on labour
amount in invoice and the sameamount of service tax calculated @ 6.18% on
labour amount as mentioned in the invoice will be paid by service recipient under
reverse charge mechanism to the Government directly. However, if the service
provider is a company, it will charge service tax @ 12.36% on labour amount in
invoice and service recipient will pay nothing under reverse charge mechanism to
the Government. If segregation is not possible, service tax rate as per chart will be
applicable.
Valuation of other Services = Gross amount charged in invoice by service
provider in respect of services (excluding taxes).
DUE DATE-POINT OF TAXATION UNDER REVERSE CHARGE (SERVICE TAX )

August 22, 2012

Reverse Charge Mechanism has a old history in service tax Act/Rules. Under this
mechanism service receiver is liable to deposit tax instead of Service provider and
in few cases Both service provider and service receiver is liable to deposit the tax in
prescribed ratio. In this post we are discussing the due date on which service tax is
liable to be deposited by the service receiver.

Service tax due date to deposit is directly linked to point of taxation means on
which tax is due as per point of taxation rule. If point of taxation is fixed then
service tax will be payable on 5th/6th of next month in which point of taxation falls.
Update :Point of taxation rules for reverse charge has been changed wef
01.10.2014
Suppose: Point of taxation is fixed on 21 August (in month of August). Then Service
tax is payable on 5th of September in case of offline payment and 6th of September
in case of online (e-payment).
However where Service tax payment can be made on quarterly basis , tax due date
is 5th/6th of next month after the end of quarter.
Now the point is when Point of taxation falls in case of reverse charge.This has been
provided in rule 7 of point of taxation rule.
Rules 7. Determination of point of taxation in case of specified services or persons.

Notwithstanding anything contained in these rules, the point of taxation in respect

of the persons required to pay tax as recipients of service under the rules made in
this regard in respect of services notified under sub-section (2) of section 68 of the
Act, shall be the date on which payment is made:
Provided that, where the payment is not made within a period of six months
of the date of invoice, the point of taxation shall be determined as if this rule does
not exist:
Provided further that in case of associated enterprises, where the person
providing the service is located outside India, the point of taxation shall be the date
of debit in the books of account of the person receiving the service or date of
making the payment whichever is earlier.

Date of payment By service Recipient is Point of taxation (general rule): As

per rule 7 of the point of Taxation Rules 2011(amended ) In case where the service
recipient is liable to pay tax , the point of taxation shall be the date of payment
against such services.
If payment is not made with in six months(exception) :However , the said
rule provides that in case the payment is not made with in 6 months from the date
of invoice , then the point of taxation shall be determine , as the rule does not
exist . Thus the point of in that case would be as per rule 3.
1. If the invoice is issued with in the period specified in rule 4A of service tax rules ,
1994(30days wef 01.04.2012 earlier 14 days) from the date of completion of
service : Date of issue of invoice or receipt of payment ,which ever is earlier.
2. If invoice is not issued with in prescribed time: Date of completion of service or
receipt of payment (payment date).

Interest is leviable if payment delayed beyond six months :In payment is not made
in with in 6 months as given above then Point of taxation is advanced as per point
number one and two given above. In such cases recipient would be liable to pay
interest on delayed payment of service tax under section 75 of the Finance act,
1994.
Example: Suppose a Service has been provided by Ram(SP) to Sham Ltd(SR) and
date of completion of service is 31.07.2012.
Determine point of taxation if
1. Payment is made in advance on 15.07.2012(Advance)
2. Payment is made on 15.01.2013(with in 6 months)
3. Payment is made on 15.03.2013(after 6 months)
Bill is raised on 15.08.2012 (with in 30days as prescribed rule 4A)
Bill is raised on 15.09.2012( After 30 days as prescribed in rule 4A)
Ans: Point of taxation in above case will be as under.
1. 15.07.2012(date of advance payment)
2. 15.01.2013(date of Payment)
3. Rule 7 first proviso read with rule 3
15.08.2012 (date of Invoice)
31.07.2012(date of completion of service)

Change in Point of Taxation Rules under Reverse Charge w.e.f. 01.10.2014:

As per existing Rule 7 of the Point of Taxation Rules, 2011, the point of taxation is
respect of persons required to pay tax as recipients of service under reverse charge
mechanism is the date on which payment is made. However, the first proviso of
said Rule mandates that where the payment is not made within a period of six
months of the date of invoice, the point of taxation shall be determined as if this
Rule did not exist, i.e., we need to fall back on Rule 3 of the Point of Taxation Rules
which states that point of taxation shall be time when invoice for service provided
or agreed to be provided is issued (completion of service where invoice is not

issued within 30/45 days as the case may be) or date of payment which ever is
earlier.
Thus, effectively as per said Rule, Point Of Taxation of services under Reverse
Charge Mechanism is the date of payment of invoice or in case invoice is not paid
within six months, the point of taxation would be the date of invoice.
Union Budget 2014-15 has amended the first proviso of Rule 7 to provide that point
of taxation in respect of reverse charge will be the payment date or the first
day that occurs immediately after a period of three months from the date of
invoice, whichever is earlier.
From the first blush, it appears that the only amendment made is curtailing of
earlier time limit of six months for payment of invoice to three months. However,
there is a positive side of amendment as well. Under the existing Rule, in case the
payment is not made within six months the point of taxation is shifted to date of
invoice and thus such person apart from payment of service tax was also obligated
to pay interest thereon. However, under the new provision though the time limit has
been curtailed to three months, but if this limit is breached the point of taxation
would be the first day that occurs immediately after period of three months and
POT is not shifted to date of invoice. This would avoid payment of interest for the
intermittent period.
It is important to note here that this amendment will only apply to
invoices issued after 1st October, 2014.
The impact of change is illustrated as under:CASE

Date
of Payment
invoice
Date
1. Payment made 16th May 12th
within six months
November
but beyond three
months of date of
invoice.
2. Payment made 16th May
after six months
of date of invoice.

30th
November

3. Payment made 16th May

within
three
months of date of
invoice.

14th Augu
st

POT
as
per
existing Rule
12th November
(i.e., date of
payment
as
payment made
within
six
months)
16th May (i.e.,
date of invoice
as
payment
made after six
months)
14th August

POT as per new

Rule
16th August (i.e.,
date immediately
after
period
of
three months from
date of invoice)
16th August (i.e.,
date immediately
after
period
of
three months from
date of invoice)
14th August

Further, a transitional Rule (new Rule 10) has also been inserted in the
Point of Taxation Rules. The same is reproduced below:-

Notwithstanding anything contained in the first proviso to Rule 7, if the invoice in

respect of a service, for which point of taxation is determinable under rule 7 has
been issued before the 1st day of October, 2014 but payment has not been made
as on the said day, the point of taxation shall,
(a) if payment is made within a period of six months of the date of invoice, be the
date on which payment is made;
(b) if payment is not made within a period of six months of the date of invoice, be
determined as if rule 7 and this rule do not exist.
The practical application of above Rule is tabulated below:-

S.
No
1
2
3

Date of
Invoice
28-092014
15-042014
02-102014

Date of
payment
05-102014
20-102014
05-112014

Point of Taxation
05-10-2014 (i.e., Date of payment, as pay- ment
made within six months) As per Rule 10
15-04-2014 (i.e., Date of invoice, as payment not
made within six months) As per Rule 10
05-11-2014 (i.e., Date of payment, as same is
made within three months) As per amended Rule
7 (Rule 10 applies only on invoices issued before
01-10-2014.)

Note:
Business Entity and Body Corporate
*a.In some cases, reverse charge is applicable only when service
receiver is business entity registered as body corporate. (Important)
- Business entity means any person ordinarily carrying out any activity relating
toindustry, commerce or any other business or profession. Thus, Government,
charitableorganisation is not business entity.
- Body Corporate Company, LLP, Cooperative Society is Body Corporate
Firm, HUF, Trust is not Body Corporate [Society registered under Societies Act is
legally not bodycorporate].

Reverse charge provisions at a glance(w.e.f. 01.10.2014)

The provisions are summarized below: (TV = Taxable Value)
Sl.
NO
.
1

Description of Service

Liability of Service Tax

Service Provider(ST
Service Receiver
rate to be charged by
service provider in
invoice)

Services
of Insurance Insurance Agent
agent [Rule2(d)(i)] (w.e.f.
01.07.2012,
FA,2012
&
before).
On 100% of TV
Nil

Insurance Company

100%

Note : As per the NN 6/2014 : included in Mega Exemption w.e.f. Sept 2014. (c)
life micro-insurance product as approved by the Insurance Regulatory and
Development Authority, having maximum amount of cover of fifty thousand rupees.
Covered: Payment to insurance agent by the insurance companies for their services.

1A

Recovery Agent Service

On 100% of TV
2

Services
of
Goods
Transport Agency (GTA) of
goods transport by road.
(w.e.f. 01.07.2012, FA,2012
& before).
Before
1.4.2015

*By road
By rail
By
vessel
By
air
(econom
y)
By
air
( other
than
econom
y)

1.4.201
5
onward
s
ST applicable on **
% of taxable value
25%
30%
30%
30%
40%
30%
40%

40%

40%

60%

*On Applicable % of TV
**Otherwise on 100% of TV

RecoveryAgent
Service
Nil

banking companyor
a
financialinstitution
or
anon - bankingfinancial
company
100%

Goods
Transport Consignor
or consignee
Agency
(one who who is
issues
consignment (i)
note)
a. factory,
b. society,
c.
registered dealer of
excisable goods,
d. bodycorporate,
e. partnershipfirm,
f. AOP
and
(ii) who pays or is liable
to
pay freight
either
himself or through his
agent for transportation
of such goods in goods
carriage.

Nil
Nil

100%
100%

*Tax payable on 25% of value if Cenvat credit has not been availed by service provider. Hence,
it is necessary to obtain certificate from the service provider (GTA) that he has not availed any
Cenvat credit. **Otherwise, service tax will be payable on 100% of the value.
Person who pays or is liable to pay freight for transportation of goods, located in taxable
territory, shall be the person who receives the service. If such person is located in nontaxable territory, the service provider of service shall be liable to pay service tax.
Covered:Transportation of goods by road through a GTA which issues a consignment note, by
whatever name called.
Excluded: Courier, express cargo, carriage of certain food/drink items, freight uptoRs. 750/- per
consignee per carriage and uptoRs. 1500/- per goods carriage.

Sponsorship
service(w.e.f.
& before)

Any
person(i.e.
01.07.2012 person
receiving
the
sponsorship
money)
Nil
On 100% of TV
Any
person
(as
above)
100%

1. Any Bodycorporate or
2. partnership firmlocated
in thetaxable territory
100%
Other than above
Nil

Covered: All sponsorships.

Excluded: Advertisement/business promotion, certain sports related sponsorships.

Services
of Arbitral ArbitralTribunal
Tribunal(w.e.f.
01.07.2012)
On 100% of TV
Nil

Business Entity having

turnover exceeding ten
lakhs per annum
100%

Covered: Any payment for any service.

Legal
Services
of IndividualAdvocate
Advocate
or
Advocate orAdvocateFirms
Firms (w.e.f. 01.07.2012)
On 100% of TV

Nil
IndividualAdvocate
orAdvocateFirms
100%

Business
turnover
lakhs
located in

Entity having
exceeding ten
per
annum,
taxableterritory.
100%
Other than Above
Nil

Covered: Advice, consultancy or assistance in any branch of law, in any manner and
includes representational services before any court, tribunal or authority.

5A

Services of director to Director

company (entry added NN
45/2012w.e.f. 7-8-2012)
On 100% of TV
Nil

Company
or
bodycorporate (w.e.f.july
2014)
100%

Covered: Any payment to non-executive directors for any service e.g. sitting fee,
reimbursements.
Excluded:Executive/directors in employment. If Company itself arranges lodging,
fooding, travelling etc. for the non-executive directors and the bill is raised in the name
of the Company. However, it may be covered under any other category e.g. car hiring
charges.
- (iva) provided or agreed to be provided by a director of a Company or a body
corporate to the said company or the body corporate;

- or the body corporate has been inserted in 2014 which covers major all directors
working under Company, LLP, Cooperative Society.

Support Services
by Government
Government or Local or Local Authority
Authority(w.e.f.
01.07.2012)
On 100% of TV
Nil

Business Entity
located
in
territory

taxable

100%

Covered: Services of police, fire, ambulance etc.

Excluded:Renting of immovable propertyand services specified in clauses (i),
(ii) and (iii) of Section 66D(a) of Finance Act, 1994.These cover postal, port, airport
and railway servicese.g: services of Department of Posts by way of speed post,
express parcel post, life insurance and agency services, services in relation to an
aircraft or a vessel, transport of goods or passengers, municipal, public convenience
and other public services like water supply, sanitation, and solid waste management.

7*

Renting or hiring of
motor vehicle designed
tocarry passengers to any
personwho is not in the
similar line of business.

Individual,HUF,
Business entityregistered
proprietary
as bodycorporate located
orpartnership
firm, in the taxableterritory.
AOP
located
intaxableterritory.
(i.e. non-company)
*On 40% of TV (w.e.f.
Nil
100%
01.10.2014 on 50% of
value)
**On 100% of TV
60% (w.e.f. 01.10.2014
40% (w.e.f. 01.10.2014
50%)
50%)

On ST liability as above

corporate entity
*(i.e. company)

Anybody

100%

Nil

*With Abatement: No CENVAT Credit is availed by Service Provider - Tax on 40% of

Value. W.e.f. 1st Oct 2014 rate will be 50% by Service Receiver.
**Without Abatement: If the service provider intends to avail CENVAT credit, he
can pay service tax on balance 60%. Thus, service receiver is liable to pay service
tax only on 40% value. W.e.f. 1st Oct 2014 rate will be 50% by provider and 50% by
Service Receiver NN 10/2014.
Covered:Hiring passenger cars, cabs, buses etc.
Excluded: Radio taxi, metered cab, three wheeler, auto rickshaw, stage carrier,
contract carriage and packaged tour, public transport not predominantly for tourism
purpose e.g. Meru cabs, bus having contract permit hired for transportation of
employees.

8*

Similar line of activity

Entire Tax payable by
Service
Provider.
Abatement benefit canbe
availed.
Supply of Manpower for
any
purpose
(w.e.f.
01.07.2012) or security
service (The words or

Any Body
100%

Any Body
Nil

Individual,
HUF, Business entity registered
proprietary
or as body corporate located
partnership firm, AOP in the taxableterritory.
located

security
service
were intaxableterritory.
added w.e.f. 7-8-2012.
(i.e. non-company)
On 100% of TV
25%

On ST liability as above
From 01.04.2015

75%

corporate
entity*(company)

Anybody

100%
Nil

Nil
100%

Covered: Payment for services of the staff seconded/deputed with the company under
an arrangement where the staff remains on the payroll of the original
employer only, payment for services of staff (not on payroll of the recipient of
service) supplied by an agent/person under an arrangement where it is placed
operationally under the superintendence or control of the recipient of service (e.g.
housekeeping staff supplied by manpower agency), all security/detective services.
Excluded: Joint employment, outsourcing the activity/service itself e.g. outsourcing
house-keeping work to an outside agency instead of getting the manpower supplied by
an agent for house-keeping work, Recruitment/placement agency service.
Service should be manpower supply i.e. under command of Principal
Employer.
- Supply of manpower means supply of manpower, temporarily or otherwise, to
another person to work under his superintendence or control. [Rule 2(g) of Service
Tax Rules, inserted w.e.f. 1-7-2012].
- Cleaning service, piece basis or job basis contract can be manpower
supply service only if the labour work under superintendence or control of Principal
Employer.
- Assessable Value: Service tax payable on salary plus PF, ESI plus
commission of labour contractor.

9*

Service portionin execution

ofWorks
Contract
(if
Cenvat credit on inputs
notavailed by SP).

Individual,HUF,
Business entityregistered
proprietary
as body corporate located
orpartnership
firm, in the taxableterritory.
AOP
located
intaxableterritory.
(i.e. non-company)
For
execution
of
50%
50%
originalWorks On 40% of
TV.
FOR Other works than
original On 60% of ST.
(w.e.f.
01.10.2014
NN
10/2014)

On ST liability as above

corporate
entity*(i.e.
company)

Anybody

100%

Nil

Construction, Job work with material, AMC covered under works contract.
Prior to 01.10.2014W.e.f. 01.07.2012::
Works contracts entered into for execution of original works - 40%; (Covered:
Any contract involving the use of labour plus material on which VAT is leviable under
any schedule of VAT Act on any material used in execution of works contract and such
contract is for any new construction; any addition and alteration to abandoned or
damaged structures on land that are required to make them workable; any erection,

commissioning or installation of plant, machinery or equipment or structures, whether

pre-fabricated or otherwise.)
Works contracts entered into for maintenance or repair or reconditioning or
restoration or servicing of any goods - 70%; (Covered: Any contract involving the use
of labour plus material on which VAT is leviable under any schedule of VAT Act on any
material used in execution of works contract and such contract is for maintenance or
repair or reconditioning or restoration or servicing of any goods e.g. AMC of movable
items/office equipments.)
For other works contracts, not covered above, including maintenance, repair,
completion and finishing services such as glazing, plastering, floor and wall tiling,
installation of electrical fittings of an immovable property - 60%. (Covered: Any
contract involving the use of labour plus material on which VAT is leviable under any
schedule of VAT Act on any material used in execution of works contract and such
contract is other two mentioned above or is for maintenance, repair, completion and
finishing services such as glazing, plastering, floor and wall tiling, installation of
electrical fittings of an immovable property e.g. interior and furnishing work, electrical
work of items other than movable ones.)

10

Services received
from Located
in
non- Located
non-taxable
taxable territory.
territory
territory(Import
of
Service)&(Incase
of
foreignservices
andservices from J&K)
(w.e.f.
01.07.2012
&
before)
Nil

in

taxable

100%

Covered: Any payment for import of taxable services from any place outside India.

(Import of Service) supersedes all other services under reverse

charge.