Wednesday, 21 May 2014

Service Tax for Construction of Residential Complex

Construction of industrial and commercial buildings was already subject to service tax. The Government included residential complexes also within the ambit with effect from June 16, 2005.
Relevant provisions
Section 65(30a) of the Act, as inserted by the Finance Act, 2005 (“Act”) defines “construction of complex” as follows:

“Construction of complex” means-
a.       construction of a new residential complex or a part thereof; or
b.      completion and finishing services in relation to residential complex such as glazing, plastering, painting, floor and wall tiling, wall covering and wall papering, wood and metal joinery and carpentry, fencing and railing, construction of swimming pools, acoustic applications or fittings and other similar services; or
c.       repair, alteration, renovation or restoration of, or similar services in relation to, ‘residential complex.’
The term ‘residential complex’ is defined in section 65(91a) of the Act as follows:
“Residential complex” means any complex comprising of-
                     i.            a building or buildings, having more than twelve residential units;
                   ii.            a common area; and
                  iii.            any one or more of facilities or services such as park, lift, parking space, community hall, common water supply or effluent treatment system
located within a premises and the layout of such premises is approved by an authority under any law for the time being in force, but does not include a complex which is constructed by a person directly engaging any other person for designing or planning of the layout, and the construction of such complex is intended for personal use as residence by such person.
Explanation: For the removal of doubts, it is hereby declared that for the purposes of this clause, -
a)      “personal use” includes permitting the complex for use as residence by another person on rent or without consideration;
b)      “residential unit” means a single house or a single apartment intended for use as a place of residence.

What is the taxable service?
Section 65(zzzh) of the Act defines the taxable service as any service provided or to be provided to any person, by any other person in relation to construction of complex.

Important:
With effect from July 01, 2010, an Explanation has been inserted below sub-clause (zzzh) of section 65(105) by the Finance Act, 2010 to clarify that unless the entire consideration for the property is paid after the completion of construction (i.e., after issuance of completion certificate by the competent authority), the activity of construction would be deemed to be a taxable service provided by the builder/promoter/developer to the prospective buyer and the service tax would be charged accordingly.   

Value of the taxable service
Under section 67 of the Act, the value of taxable service is required to be computed in the following manner:
·         Where the provision of service is for a consideration received wholly in money, the value shall be the gross amount charged by the service provider for provision of service. The term ‘consideration’ includes any amount payable for the services provided or to be provided. The term ‘gross amount charged’ shall include (i) such amount received towards the service before, during and after provision of such service; and (ii) payment by cheque, credit card, deduction from account and any form of payment by issue of credit notes or debit notes and book adjustment.
·         Where the gross amount charged is inclusive of service tax payable, the value shall be such amount as, with the addition of tax payable, is equal to the gross amount charged.
·         Where the provision of service is for a consideration which is not wholly or partly consisting of money, the value shall be such amount in money as, with the addition of service tax charged, is equivalent to the consideration.
·         Where the provision of service is for a consideration which is not ascertainable, the value shall be the amount as maybe determined in the manner prescribed in the Valuation Rules.

Rate of Service Tax

12.36% 

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