A Knowledge Workshop-Presentation II dated 14th July,2012

Corporate Knowledge
Foundation

Presents
A Knowledge Workshop
On
“New Regime of Service Taxation in India”
Conducted by
Dr. Sanjiv Agarwal
FCA, FCS

Saturday,
14th July,2012
New Delhi © Dr. Sanjiv Agarwal

Corporate Knowledge Foundation

SESSION - II

Negative List of Services

&

Exempted Services

2

Scope of Service Tax

Services on which Service Tax shall be attracted
comprise of :
 Those services which satisfy the definition of service u/s
65B (44)
 Nine specified declared services u/s 66E
 Those services which do not find place in negative list of
services u/s 66D
 Those services which are not exempt from levy of
Service Tax under Notification No. 25/2012-ST dated
20.06.2012
to be contd….

3

Scope of Service Tax

Services on which no Service Tax shall be payable comprise
of :
• Service which are specifically excluded from the scope of
definition of service itself u/s 65(44).
• 17 broad services specified in the negative list of services
u/s 66D.
• Services which are exempt from levy of Service Tax under
N. No. 25/2012-ST dated 20.06.2012.
• Specified services otherwise exempt under specific
notifications.
• Activities where service provider and service receiver are
in non –taxable territory
4

Examples of new activities
which may be taxed

• Non commercial construction for non-government purpose
• Private roads
• Residential construction of more than one unit
• Commercial artists/performers
• Actors, directors
• Reality show judges
• Tourism boats
• Board director’s sitting fee
• Non-compete fee
• Arbitrators to business entities
• Banking services to government
• Unrecognized IPRs
to be contd..
5

Examples of new activities which
may be taxed

• Discourses and lectures
• Services to RBI
• Hotel Telephone Calls
• Matrimonial sites
• Astrologers

6

Negative list of Services

What is negative list

• Defined in new section 66D

• Section 66D Specifies seventeen 17 broad categories of
services.

• Effective from 1-7-2012

• If an activity meets the charactertics of ‘ service ‘, it is taxable
unless specified in Negative List.

7
• Based on socio-economic–tax criterion

Consideration in Negative List
Socio – Economic Considerations in Negative list

• Administrative considerations: taxation of Government, difficult to
tax sectors e.g. margin-based financial services.
• Under contractual obligations: Specified international bodies and
diplomatic missions
• Welfare considerations: welfare of vulnerable sections of society,
essential education, public health; public transport, services by
non-profit entities, religious services, promotion of art, culture and
sports.
• Economic considerations: transport of export goods, services
meant for agriculture, animal husbandry and infrastructure
development.
• Explicit activities in the nature of services, which are within the
taxing powers of States: betting and lotteries, tolls.

8

Sectors in Negative List

Negative list of services is drawn from seven sectors, viz.
• services provided by specified person ie, Government
• social welfare & public utilities
• financial sector
• transportation
• construction & real estate
• education
• health care
• others & miscellaneous

9

Services by Government or a local
authority
Services by Government or a local authority excluding the following
services to the extent they are not covered elsewhere:

• Services by the Department of Posts by way of speed post,
express parcel post, life insurance and agency services provided
to a person other than Government;

• Services in relation to an aircraft or a vessel, inside or outside the
precincts of a port or an airport;

• Transport of goods or passengers; or

• Support services provided to business entities
10

to be contd..

Service provided by Government
or Local Authority
• Most of services provided by Central / State Governments
exempt from service tax.
• But following services are taxable -
 Department of posts - speed post, express parcel, life
insurance and agency service to non government
business entity but basic mail, money orders, operation
of saving accounts ,pension payment etc services are
covered in negative list
 In relation to vessel or aircraft service within/outside
port/airport
 Transport of goods and/ or passengers
 Support service to business entities
To be contd…..

Service provided by Government or
Local Authority
• Services by government as sovereign functions (grant of
licensing rights or audit of government, passport etc.)
• Excludes corporations formed under Central Acts or State
Acts or various Government companies registered under
Companies Act, 1956 or autonomous institutions set up by
a Special Acts
• Government Department needs to be registered and to
pay tax on support services of
 Renting of immovable properties
 Speed post, express parcel, life insurance.
 Transport of goods and/ or passengers
 Services in relation to vessel or aircraft
• For other services, government not liable to pay service tax
as tax paid by service recipient in reverses charge (N. No.
30)
To be contd…..

Service provided by Government or
Local Authority

“ Support services" means
 infrastructural,
 operational,
 administrative,
 logistic,
 marketing or
 any other support of any kind comprising functions that
entities carry out in ordinary course of operations
themselves but may obtain as services by outsourcing
from others for any reason whatsoever
 shall include advertisement and promotion, construction
or works contract, renting of immovable property,
security, testing and analysis;
• Services provided by Government Security agencies are covered
under support service - under reverse charge, Service Receiver is
liable to tax.

Service by Reserve Bank of
India
• All services provided by RBI are in Negative List
• Service Provided to RBI is taxable unless covered
in negative list.
• Service provided by banks to RBI taxable unless
covered in Negative List or exempted services

Services by a foreign diplomatic
mission located in India
• Services by diplomatic mission of any country located in
India
• Does not cover services provided by any office or
establishment of an International organization (Section 3 of
United Nation Privileges & Immunities Act 1947)
• Example- UNESCO, UNICEF, IMF, IBRD etc
• Notification No. 27/2012- ST dated 20.6.2012 conditionally
exempts service provided by any person
 for the official use of a provision of a foreign diplomatic mission or
consular post in India
 for personal use or use of the family member of diplomatic agents
or career consular officers posted in India

Service relating to Agriculture or
Agricultural Produce
services relating to agriculture by way of—
(i) agricultural operations directly related to production of any agricultural
produce including cultivation, harvesting, threshing, plant protection
or seed testing;
(ii) supply of farm labour;
(iii) processes carried out at an agricultural farm including tending,
pruning, cutting, harvesting, drying, cleaning, trimming, sun drying,
fumigating, curing, sorting, grading, cooling or bulk packaging and
such like operations which do not alter the essential characteristics of
agricultural produce but make it only marketable for the primary
market;
(iv) renting or leasing of agro machinery or vacant land with or without a
structure incidental to its use;
(v) loading, unloading, packing, storage or warehousing of agricultural
produce;
(vi) agricultural extension services;
(vii) services by any Agricultural Produce Marketing Committee or Board
or services provided by a commission agent for sale or purchase of
agricultural produce;
to be contd…


The Services relating to agriculture or agriculture
produce specified in negative list-
 agricultural operations directly related to production of any
agricultural produce including cultivation, harvesting, threshing,
plant protection or seed testing;
 supply of farm labour;
 processes carried out at the agricultural farm including tending,
pruning, cutting, harvesting, drying cleaning, trimming, sun drying,
fumigating, curing, sorting, grading, cooling or bulk packaging and
such like operations which do not alter essential characteristics of
agricultural produce but makes it only marketable for the primary
market not for retail market; (e.g. cleaning of Wheat)
to be contd …….

• renting of agro machinery or vacant land with or without a
structure incidental to its use (e.g. green house, storage
shed.)
• loading, unloading, packing, storage and warehousing of
agricultural produce;
• agricultural extension services (application of scientific
research, farmer education & training)
• services provided by any Agricultural Produce Marketing
Committee or Board (APMC) for agriculture or agricultural
produce but does not include non -agricultural activities
(e.g. renting of shops or other property or services
provided by commission agent for sale or purchase of
agricultural produce)
to be contd …….


Agriculture -Section 65 B(3)
Cultivation of plants and rearing of all life-forms of animals
except the rearing of horses, for food, fiber, fuel, raw
material or other similar products

Agriculture Produce -Section 65B(5)
any produce of agriculture on which either no further
processing is done or such processing is done as is usually
done by a cultivator or producer which does not alter its
essential characteristics but makes it marketable for
primary market (E.g. Plantation crops like rubber, tea or
coffee but does not include potato chips or tomato ketchup)
to be contd …….

Trading of Goods
• Trading of goods is not a taxable service, it being a sale
and not a service.
• If a transaction is a sale, it is not a service and vice versa
• Transfer of title in goods is crucial
• Activities of a commission agent / clearing and forwarding
agent who sells goods on behalf of another for a
commission are not trading of goods (Title of goods does
not pass)
• Forward contracts are in the nature of trading of goods.
• Future contracts are not trading of goods
to be contd …….

Trading of Goods
Goods - Section 65B(25)
“goods" means
• every kind of movable property
• other than actionable claim and
• money
• includes securities, growing crops, grass, and
things attached to or forming part of the land
which are agreed to be severed before sale or
under the contract of sale

Process amounting to manufacture or
production of goods
► process amounting to manufacture or production of goods" means a process
on which duties of excise are leviable under section 3 of the Central Excise
Act, 1944 or any process amounting to manufacture of alcoholic liquors for
human consumption, opium, Indian hemp and other narcotic drugs and
narcotics on which duties of excise are leviable under any State Act for the
time being in force.

► Covers manufacturing activity carried out on contract or job work basis
where
 Transfer of title of goods is not involved
 Duties of excise are leviable on such process

22

What is Excisable Goods
► “excisable goods” means goods specified in the First
Schedule and the Second Schedule to the Central Excise Tariff
Act, 1985 as being subject to a duty of excise and includes salt
► Mobility and marketability are essential conditions
► Goods includes any article, material or substance which is
capable of being bought and sold for a consideration and such
goods shall be deemed to be marketable.

Exemption Service - Clause 30
Carrying out an intermediate production process as job work in relation to
-
(a) agriculture, printing or textile processing;
(b) cut and polished diamonds and gemstones; or plain and studded
jewellery of gold and other precious metals, falling under Chapter 71 of
the Central Excise Tariff Act ,1985 (5 of 1986)
(c) any goods on which appropriate duty is payable by the principal
manufacturer or
(d) processes of electroplating, zinc plating, anodizing, heat treatment,
powder coating, painting including spray painting or auto black, during
the course of manufacture of parts of cycles or sewing machines upto an
aggregate value of taxable service of the specified processes of one
hundred and fifty lakh rupees in a financial year subject to the condition
that such aggregate value had not exceeded one hundred and fifty lakh
rupees during the preceding financial year

Selling of space or time slots for
advertisements
Selling of space or time slots for advertisements other than
advertisements broadcast by radio or television

This entry in negative list should qualify the following tests –
• involves selling of space (in case of print media)
• involves selling of time slots ( in case of electronic media)
• purpose of selling time slots / space to be for advertisements
(publicity / sales promotion, awareness etc.)
• excludes broadcast by radio or television ( i.e. broadcast will be
taxable)
to be contd …….

advertisements
Taxable Non-taxable
Sale of space or time for Sale of space for advertisement in
advertisement to be broadcast on print media
radio or television
Sale of time slot by a broadcasting Sale of space for advertisement in bill
organization boards, public places (including
stadia), buildings, conveyances, cell
phones, automated teller machines,
internet

Aerial advertising

Presentation made in person

advertisements
“Advertisement" means
• any form of presentation for promotion of,
• or bringing awareness about,
• any event,
• idea,
• immovable property,
• person, service,
• goods or actionable claim through
• newspaper, television, radio or any other means
• but does not include any presentation made in person;
• Services provided by advertisement agencies relating to
preparation / designing etc of advertisements are taxable.
• Print media includes newspaper and books.

Service way of access to a road or a
bridge on payment of toll charges

• Only covers toll charges for access to road and bridge
• Includes National highways or state highways.
• Toll on other roads not in negative list
• Collection charges or service charges paid to any toll
collection agency are not covered under negative list
• Dose not include services used for providing such service

Betting, Gambling or Lottery
Betting or Gambling means
• putting on stake something of value,
• particularly money,
• with consciousness of risk and hope of gain on the outcome of a
game or a contest,
• whose result may be determined by chance or accident, or on the
likelihood of anything occurring or not occurring
• Betting is a form of wagering contract in which money or money’s
worth is made payable by the parties on the result of an uncertain
event, usually a game or sport
• Gambling means playing game of chance for money or risky action
undertaken with the hope of success
• Lottery is a game of chance (e.g. lottery, bingo, lotto etc.) which may
include online games

to be contd …….

Betting, Gambling or Lottery

• Auxiliary services for organizing or promoting betting or
gambling events are not covered in negative list
• State subject covered in list II
• Actionable claim
• In Union of India & Others v. Martin Lottery Agencies Ltd
(2009) 14 STR 593 (Supreme Court), it was held that
service tax can not be levied on sale of lottery ticket
• In Martin Lottery Agencies Ltd. v. Union of India (2007) 8
STR 561 (Sikkim), it was held that petitioner was not
rendering services in relation to promotion of client’s goods
and service tax liability did not arise

Admission to entertainment events
and access to amusement facilities

‘Entertainment event’ if it is intended (may not
necessarily provide) to provide any one or more of
the following to the recipients / viewers / audience
• recreation
• pastime
• fun , or
• enjoyment

to be contd …….

Admission to entertainment
events and access to amusement
facilities

This could be by way of –
• exhibition of cinematographic film
• circus
• concerts
• sporting events
• pageants
• award functions
• dance performance
• musical performance
• theatrical performances – drama, ballets or any such
event / programme.
to be contd …….


“Amusement facility" means
• a facility where fun
• recreation is provided by means of rides
• gaming devices
• bowling alleys in amusement parks
• amusement arcades
• water parks
• theme parks
• such other places
• but does not include a place within such facility where
other services are provided
to be contd …….


• Amusement means entertainment, diversion, pastime,
sport etc.
• Theatrical performances need not be performed in
theatre
• Standalone amusement ride in a mall – fun or recreation by
means of ride – covered under amusement – excluded
• Membership of club which provides amusement facilities -
excluded
• Event manager for organizing an entertainment event or
entertainment is not cover in this category

Transmission or distribution of
Electricity by an electricity
transmission or distribution utility

• Provided by Electricity Transmission or Distribution
utility
• Covers both –
• Transmission
• Distribution
• Installation of gensets or similar equipment by
private contractor for distribution - taxable
• Charges collected by developer or a housing
society for distribution of electricity within a
residential complex - taxable but excluded if it acts
as a licensed authority

Specified services relating to
education
• Service by way of -
i. Pre-school education and education up to higher
secondary school or equivalent
ii. Education as a part of a prescribed curriculum for
obtaining a qualification recognized by law
iii. Education as a part of an approved vocational
education course
• Conduct of degree courses by colleges, universities or
institutions which lead to grant of qualifications
recognized by law

to be contd …….

education
Approved vocational education course
 a course run by an industrial training institute or an industrial
training centre affiliated to the National Council for Vocational
Training, offering courses in designated trades as notified under the
Apprentices Act, 1961
 a Modular Employable Skill Course, approved by the National
Council of Vocational Training, run by a person registered with the
Directorate General of Employment and Training, Ministry of
Labour and Employment, Government of India
 a course run by an institute affiliated to the National Skill
Development Corporation set up by the Government of India

to be contd …….

education
• Education upto higher secondary school or equivalent are
in negative list.
• Services provided to or by an educational institution for
Auxiliary educational services and renting of immovable
property – exempted under mega notification
Negative list will not include –
• Private tuitions
• Education as a part of prescribed curriculum for
obtaining qualification recognized by law of a foreign
county
• Services provided to educational institutions
• Placement services
to be contd …….

education
Education related services not in negative list but exempt
from tax under Notification No. 25/2012-ST dated
20.06.2012
• Transportation of students to / from institutions
• Provision of mid-day meal in schools
• Admission related services to educational institutes
where education services are exempt.
• Coaching / training in recreational activities of arts,
culture or sports.

Services by way of renting of residential
dwelling for use as residence

Renting coves all types of arrangements in relation to immovable
property with or without its transfer of possession or control and
whether wholly or partly. It would cover / include –
• allowing
• permitting
• granting access / entry / occupation
• use of facility
• letting
• leasing
• licensing, or
• other similar arrangements
(such as right to use, sub-lease, space sharing etc.)

to be contd …….


Renting of certain kinds of property already covered in
the negative list
• renting of vacant land, with or without a structure
incidental to its use, relating to agriculture.
• renting of residential dwelling for use as residence
• renting out of any property by Reserve Bank of India
• renting out of any property by a Government or a local
authority to non-business entity

to be contd …….


• Residential dwelling not defined but includes residential
accommodation
• does not include hotel, motel, inn, Guest house, camp site,
lodge, house boat or other placement temporary stay
• Residential dwelling used partly as a residence and partly
for non residential purpose- treated as bundled service
• Residential unit – independent residential unit with specific
facilities for living, cooking and sanitation

to be contd …….

Financial Services

Services by way of—
(i) extending deposits, loans or advances in so far as the
consideration is represented by
way of interest or discount;
(ii) inter se sale or purchase of foreign currency amongst
banks or authorised dealers of foreign exchange or
amongst banks and such dealers;

to be contd …….

Financial Services
• Transactions in money outside the ambit of ‘service’
• Any activity related to a transaction in money by way of its
use or conversion by cash or by any other mode, from one
form , currency or denomination to another form, currency
or denomination would not be treated as a transaction in
money if a separate consideration is charged for such an
activity
• Service tax levied on service charges for transactions in
money including of charges for making of drafts, letter of
credits issuance charges, service charges relating to
issuance of CDs/ CPs etc
• Interest rate swaps and foreign exchange swaps are
excluded being securities and hence excluded
to be contd …….

Financial Sector
• Only interest and discount are in negative list
• Interest on
 Money borrowed
 Debt incurred
 Deposit
 Claim / obligation/ similar right
• Service charge / fee/ commission not covered (e.g. pre
payment fee, late fee, cheque bounce charges)
• interest on credit facility not utilized (commitment charges )
not covered
• Bill discounting – only discount covered
to be contd …….

Financial Services
• Any charges over and above interest/ discount taxable
• Purchase/ sale of foreign currency between banks and
authorized dealers under negative list
• Examples of services in negative list-
 Fixed deposits or saving deposits or any other such deposits in a
bank for which return is received by way of interest
 Providing a loan or over draft facility for in consideration for
payment of interest
 Mortgages or loans with a collateral security to the extent that the
consideration for advancing such loans or advances are
represented by way of interest
 Corporate deposits to the extent that the consideration for
advancing such loans or advances are represented by way of
interest or discount

Services relating to transportation of
passengers
Services by-
• a stage carriage;
• railways in a class other than
(i) first class; or
(ii) an AC coach; ( now exempt under Notification No 43/2012)
• metro, monorail or tramway;
• inland waterways;
• public transport, other than predominantly for tourism
purpose, in a vessel, between places located in India;
and
• metered cabs, radio taxis or auto rickshaws.
to be contd …….

passengers
• ‘Stage Carriage’ is defined in section 2(40) of Motor
Vehicles Act, 1988. It means a motor vehicle constructed
or adapted to carry more than six passengers excluding the
driver for hire or reward at separate fares paid by or for
individual passengers, for the whole journey or for stages
of the journey
• National waterways covered in inland waterways
• Metered cab - any contract carriage on which an automatic
device, of the type and make approved by the State
Transport Authority, is fitted which indicates reading of the
fare chargeable at any moment and that is charged
accordingly under the conditions of its permit issued under
the Motor Vehicles Act, 1988
to be contd …….

passengers
Covered under negative list Not Covered under negative
list
Motor vehicles on hire to state Motor vehicles to state transport
transport undertaking (more taken undertaking
12 passengers)

Exemption to Transport of No exemption for Tourism,
passengers by a contract carriage conducted tours, chartered or hire

Service relating to transportation by
Goods
services provided in relation to transportation of
goods specified in the negative list
• by road except the services of
(i) a goods transportation agency or
(ii) a courier agency
• by aircraft or vessel from a place outside India up to the
customs station of clearance in India; or
• by inland waterways (agents covered)
to be contd …….

Goods
• Services provided by GTA taxable except under
separate exemption available for
• fruits, vegetables, eggs, milk, food grains or pulses in a goods
carriage;
• goods where gross amount charged on a consignment
transported in a single goods carriage does not exceed one
thousand five hundred rupees; or
• goods where gross amount charged for transportation of all
such goods for a single consignee in the goods carriage does
not exceed rupees seven hundred fifty.
• Courier services – Express cargo service, angadia
– taxable
to be contd …….

Goods

Nature of service relating to Whether covered in the
transportation of Goods negative list entry
By railways No
By air within the country or No
abroad
By a vessel in the coastal No
waters
By a vessel on a national Yes
waterway
Services provided by a GTA No

Funeral, Burial, Crematorium or Mortuary
Services including Transportation of the
deceased
• Funeral
• Burial
• Crematorium
• Mortuary
• Transportation of deceased

Exemptions under Service Tax
General Exemptions
Small Scale Exemption
• The threshold exemption limit of Rs. 10 lakh continues to
exist and it is over and above the exemptions notified in
Notification No. 25/2012-ST dated 20.6.2012.
• W.e.f. 1.4.2012, aggregate value of Rs. 10 lakh would
mean the sum total of value of first consecutive invoices
issued during a financial year, but does not include value
charged in invoices towards such services which are
exempt from whole of service tax. (Refer Notification No.
33/2012-ST dated 20.6.2012)

to be contd….

Exemption under Service Tax
General Exemptions
• W.e.f.1.07.2012, Notification No. 6/2005 as
amended shall no longer be applicable. There is a
change in scope of aggregate value which shall
mean as follows and subject to following
conditions-
 total of value of taxable services
 value shall be as charged in first consecutive invoices
issued during financial year
 value charged in invoices issued for taxable services
which are exempt from whole of Service Tax shall be
excluded in determining the aggregate value

General Exemptions
Exemption for Exporters/SEZ
► Transportation of export goods by Goods Transport
Agency in a goods carriage received by an exporter for
transport of goods. (Refer Notification No. 31/2012- ST
dated 20.6.2012)

► Refund of service tax paid on all input taxable services
received by an exporter of goods and used for export of
goods, subject to certain specified conditions. (Refer
Notification No. 39/2012-ST dated 20.6.2012)

► Taxable services, received by a unit located in a Special
Economic Zone or Developer of SEZ for the authorised
operations. (Refer Notification No. 40/2012-ST dated
20.6.2012)

General Exemptions
Exemption for Exporters/SEZ
► Rebate of Service Tax paid on taxable services received by
exporter of goods and used for export of goods, subject to
conditions (Refer Notification No. 41/2012-ST dated
29.6.2012)
► Exemption to services provided by commission agent
located outside India and engaged by Indian exporter for
promotion of export goods exported upto Service Tax
calculated on 10% of free on board value of export goods
(Refer Notification No. 42/2012-ST dated 29.6.2012)

General Exemptions
Exemption to Import of Technology
► Taxable service involving import of technology, from so
much of service tax, as is equivalent to the extent of
amount of cess payable on the said transfer of technology
under the provisions of section 3 of the Research and
Development Cess Act, 1986.(Refer Notification No.
14/2012-ST dated 17.3.2012)

Exemption for Services to Foreign Diplomatic
Mission
► Taxable services provided for the official use of a foreign
diplomatic mission or consular post in India, or for personal
use or for the use of the family members of diplomatic
agents or career consular officers posted therein. (Refer

General Exemptions
Exemption to Services by TBI or STEP
► Taxable services provided by a Technology Business Incubator (TBI)
or a Science and Technology Entrepreneurship Park (STEP)
recognized by the National Science and Technology Entrepreneurship
Development Board (NSTEDB) of the Department of Science and
Technology, Government of India. (Refer Notification No. 32/2012-ST
dated 20.6.2012)

Exemption to Renting of an Immovable Property
► Taxable service of renting of an immovable property, from so much of
the service tax leviable thereon, as is in excess of the service tax
calculated on a value which is equivalent to the gross amount charged
for renting of such immovable property less taxes on such property,
namely property tax levied and collected by local bodies. (Refer

General Exemptions
Exemption to Railway Services
 Taxation of services of passenger transportation
by railways in first class / AC coach and
transportation of goods by railways exempt upto
30 September, 2012 (Refer Notification No.
43/2012-ST dated 2.7.2012)

Specific Exempted Services
(Vide mega Exemption Notification No.
25/2012-ST dated 20.6.2012)
► W.e.f. 1.7.2012
► Covers 39 specific exemptions
► Negative List services – not taxable at all ;
can be amended only by parliament
► Exempted services – taxable but exempt
under notification; can be modified by
notification.

Services Provided to the United Nations
or a Specified International Organization
Services Provided to the United Nations or a Specified
International Organization
• Service provided to all international organization are not
exempt but service to only specified international
organizations of united Nations (privileges and immunities
Act, 1947) are exempt
• Service provided for official use of foreign diplomatic
mission/ counselor post and personal use are exempt vide
N. No. 27/2012-ST dated 20.6.2012

Health Care Services

Health care services by a clinical establishment, an authorised
medical practitioner or para-medics
What is health care
• “Health care services” means any service by way of diagnosis or
treatment or care

• For illness, injury, deformity, abnormality or pregnancy in any
organization system of medicine and includes services by way of
supply of meals for the patient or transportation of the patient to and
from a clinical establishment

• Does not include hair transplant or cosmetic or plastic surgery,
except when undertaken to restore or to reconstruct anatomy or
functions of body affected due to congenital defects, developmental
abnormalities, injury or trauma.


► All health care services shall not be exempt but
only recognized systems of medicine are covered
under exemption.
► Recognized systems of medicine include
• Allopathy
• Yoga
• Naturopathy
• Ayurveda
• Homeopathy
• Siddha
• Unani
• Any other system of medicine that may be recognized by
Central Government.


“Authorised medical practitioner” means
 any medical practitioner registered with any of the Councils of the
recognised system of medicine
 includes medical professional having the requisite qualification to
practice in any recognised system of medicine as per any law for the
time being in force.
 medical practitioner is a physician or surgeon

Health care Services by a Clinical
Establishment or Authorized Medical
Practitioner or Para medics
“Clinical establishment” means
• a hospital
• nursing home
• clinic,
• sanatorium or an institution by, whatever name called,
• that offers services, or facilities requiring diagnosis or treatment or care for
• illness,
• injury,
• deformity,
• abnormality or
• pregnancy,
• in any recognised system of medicine, established and administered or
maintained by any person or a place established as an independent entity
or a part of an establishment to carry out diagnostic or investigative
services of diseases.


• Paramedics are trained health care professionals,
e.g. nursing staff, physiotherapists, technicians,
lab assistants etc.
• The services to be exempt must
• be health care services
• be provided by -
(i) a clinical establishment, or
(ii) an authorised medical practitioner, or
(iii) para-medics
• Exempted under Notification No. 30/2011-ST
dated 25.4.2011 w.e.f. 1.5.2011.

Health Care of Animals or Birds

Services by a veterinary clinic in relation to health care of
animals or birds
• Health care services for animals and birds - Exempted
• Such services are generally provided by a veterinary clinic
• ‘Veterinary’ implies relating to the diseases, injuries and
treatment of farm and domestic animals

Services by way of Charitable Activities

Services by an entity registered under section 12AA of the Income tax
Act, 1961 by way of charitable activities

“Charitable activities”- Clause (k) means activities relating to –
(a) public health by way of –
• care or counselling of -
(i) terminally ill persons or persons with severe physical
or mental disability
(ii) persons afflicted with HIV or AIDS, or
(iii) persons addicted to a dependence-forming substance
such as narcotics drugs or alcohol or
• public awareness of preventive health, family planning or
prevention of HIV infection
(b) advancement of religion or spirituality


(c) advancement of educational programmes or skill
development relating to,-
(I) abandoned, orphaned or homeless children
(II) physically or mentally abused and traumatized persons
(III) Prisoners or
(IV) persons over the age of 65 years residing in a rural area
(d) preservation of environment including watershed, forests
and wildlife or
(e) advancement of any other object of general public utility
up to a value of twenty five lakhs rupees in any FY
provided that total value of such activities had not
exceeded twenty five lakhs rupees during the preceding FY


Conditions for this exemption -
 services should be provided by an entity
registered u/s 12AA of Income Tax Act, 1961,
and
 services should be charitable activities (as
above)

Services relating to Religious Place and
Religious Ceremony
Services by a person by way of-
 renting of precincts of a religious place meant for general public
or
 conduct of any religious ceremony
• Renting of precinct of a religious place as well as conduct of any
religious ceremony, both shall be exempt
• Religious place is a place which is primarily meant for conduct of
prayers or worship pertaining to a religion
• ‘Precincts’ means an area within the walls or perceived boundaries
of a particular building or place; an enclosed or clearly defined area
of ground around a cathedral, church, temple, college etc.

Services relating to Religious Place and
Religious Ceremony

• Exemption is available only if the place is meant for general
public
• General public means the body of people at large
sufficiently defined by some common quality of public or
impersonal nature
• E.g.- if a marriage is performed in precincts of a church by
renting of that place, it would be exempt

Services provided by arbitral
tribunal
Services provided by-
(a) an arbitral tribunal to -
(i) any person other than a business entity; or
(ii) a business entity with a turnover up to rupees ten lakh in the
preceding financial year;
(b) an individual as an advocate or a partnership firm of advocates by
way of legal services to,-
(i) an advocate or partnership firm of advocates providing legal
services ;
(ii) any person other than a business entity; or
(iii) a business entity with a turnover up to rupees ten lakh in the
preceding financial year; or
(c) a person represented on an arbitral tribunal to an arbitral tribunal

Services provided by arbitral
tribunal
Taxability for Arbitral Tribunal
Sole / Panel
to Arbitral Tribunal exempt
to any person (non business entity) exempt
to business entity (turnover upto 10 lakh) exempt
to business entity (turnover > 10 lakh) taxed under reverse charge
Taxability for advocates
Individual / firm
to Individual / firm exempt
to business entity (turnover upto 10 lakh) exempt
to business entity (turnover > 10 lakh) taxed under reverse charge
• Firm includes LLP
• Effectively, no tax to be paid by advocates / arbitral tribunal
• Legal services – advice, consultancy or assistance in any branch of law in any
manner, includes representational services (N. No. 25/2012-ST dated
20.6.2012)

Services by way of technical testing or
analysis of newly developed drugs
Services by way of technical testing or analysis of newly developed drugs,
including vaccines and herbal remedies, on human participants by a
clinical research organisation approved to conduct clinical trials by the
Drug Controller General of India
Conditions to be satisfied –
(a) service of conduct of technical testing and analysis
(b) service in relation to newly developed drugs/vaccines/herbal remedies
(c) service on human participants
(d) service by clinical research organization approved by Drug Controller
General of India.

Services of training or coaching in
recreational activities
Services by way of training or coaching in recreational activities relating to
arts, culture or sports
• Exemption is to training or coaching
Such coaching or training must relate to any one or more of
—
 arts,
 culture,
 sports
• Activities by performing artists in folk or classical art
forms of music, dance or theatre are not liable to
service tax

Services provided to / by educational
institution
Services provided to or by an educational institution in respect of
education exempted from service tax, by way of -
 auxiliary educational services or
 renting of immovable property
• Auxiliary education services shall cover the services in relation to
educational activities only and include –
i. any service relating to imparting any
► skill
► knowledge
► education
► development of course conduct
► other knowledge enhancement activity
i. whether for students or faculty
ii. out sourced activities ordinarily carried out by educational institutions

Services provided to / by educational
institution
iii. services in relation to –
► admission
► conduct of examination
► catering of students under any mid day meal scheme
sponsored by Government
► Transportation of students or faculty

iii. Services in relation to catering under mid day scheme and
transportation were hitherto exempt under different notifications
under outdoor catering services and tour operator’s services

Services provided to a recognised sports
body
Services provided to a recognized sports body by-
a) an individual as a player, referee, umpire, coach or team manager
for participation in a sporting event organized by a recognized sports
body;
b) another recognised sports body;
► Recognized sports body include IOA, SAI, Intl0A, etc
► Services by individual player, referee etc to sports body are
exempt for participation in event
► Services by one recognized sport body to other is exempt
► Services by individuals such as selectors, commentators,
curators, technical experts is not exempt
► Services provided to unrecognized franchisee of sport event
taxable (eg: IPL )

Services by way of sponsorship of
sporting events
Services by way of sponsorship of sporting events organised-
a) by a national sports federation, or its affiliated federations, where
the participating teams or individuals represent any district, state
or zone;
b) by Association of Indian Universities, Inter-University Sports
Board, School Games Federation of India, All India Sports
Council for the Deaf, Paralympic Committee of India or Special
Olympics Bharat;
c) by Central Civil Services Cultural and Sports Board;
d) as part of national games, by Indian Olympic Association; or
e) under Panchayat Yuva Kreeda Aur Khel Abhiyaan (PYKKA)
Scheme

Services by way of sponsorship of
sporting events
• Events, i.e., tournaments or championships organized only
by specified bodies in relation to games, sport, cultural
events etc – Exempted

• Any sponsorship of event organized by any other body like
BCCI arranging IPL cricket tournament –Not Exempted

• Vide N. No. 30/2012-ST dated 20.6.2012, entire service tax
is payable by the body corporate or partnership firm
receiving the service in India under reverse charge method

Services provided to the Government, a
local authority or a governmental authority
Services provided to the Government, a local authority or a governmental
authority by way of construction, erection, commissioning, installation,
completion, fitting out, repair, maintenance, renovation, or alteration of -
a) a civil structure or any other original works meant predominantly for
use other than for commerce, industry, or any other business or
profession;
b) a historical monument, archaeological site or remains of national
importance, archaeological excavation, or antiquity specified under the
Ancient Monuments and Archaeological Sites and Remains Act, 1958
(24 of 1958);
c) a structure meant predominantly for use as (i) an educational, (ii) a
clinical, or (iii) an art or cultural establishment;
d) canal, dam or other irrigation works;
e) pipeline, conduit or plant for (i) water supply (ii) water treatment, or (iii)
sewerage treatment or disposal; or
f) a residential complex predominantly meant for self-use or the use of
their employees or other persons specified in the Explanation 1 to
clause 44 of section 65 B of the said Act;

► Government (States or Central) or any local authority (such as
municipal corporation, development authority etc) or governmental
authority (such as Revenue Board, Water Board etc) shall be exempt
from levy of service tax on
• construction,
• erection,
• commissioning,
• installation,
• completion,
• fitting out,
• repair,
• maintenance,
• renovation, or
• alteration,
in relation to specified structure, buildings or complex.


► Construction of buildings or structures such as hospitals or educational
institutes for the government or local authority or governmental
authority –Exempt
► if such construction is for others – Taxable
► A civil structure or any other original works meant predominantly for
use other than for commerce, industry, or any other business or
profession – Exempt
► If client is other than the Government, a local authority or a
governmental authority, service tax is required to paid
► Service tax is payable on construction of a residential complex having
more than one single residential unit

Services provided by way of construction, erection,
commissioning, installation, completion, fitting out,
repair, maintenance, renovation, or alteration
Services provided by way of construction, erection, commissioning,
installation, completion, fitting out, repair, maintenance, renovation, or
alteration of,-
a) a road, bridge, tunnel, or terminal for road transportation for use
by general public;
b) a civil structure or any other original works pertaining to a
scheme under Jawaharlal Nehru National Urban Renewal
Mission or Rajiv Awaas Yojana;
c) a building owned by an entity registered under section 12 AA of
the Income tax Act, 1961(43 of 1961) and meant predominantly
for religious use by general public;
d) a pollution control or effluent treatment plant, except located as a
part of a factory; or
e) a structure meant for funeral, burial or cremation of deceased

Services provided by way of construction, erection,
commissioning, installation, completion, fitting out,
repair, maintenance, renovation, or alteration

• Construction of roads for use by general public - Exempt
• Construction of roads which are not for general public use e.g.
construction of roads in a factory, residential complex etc –Taxable
• If assessee is constructing such structures for the government, a local
authority or a governmental authority – Exempt
• If assessee is constructing for others – Taxable
• construction of a building owned by an entity registered under section
12 AA of the Income tax Act, 1961 and meant predominantly for
religious use by general public – Exempt
• Repair, maintenance of airports, ports and railways -Taxable

Services by way of construction, erection,
commissioning, or installation of original works

Services by way of construction, erection, commissioning, or installation
of original works pertaining to,-
a) an airport, port or railways, including monorail or metro;
b) a single residential unit otherwise than as a part of a residential
complex;
c) low- cost houses up to a carpet area of 60 square metres per house in
a housing project approved by competent authority empowered under
the ‘Scheme of Affordable Housing in Partnership’ framed by the
Ministry of Housing and Urban Poverty Alleviation, Government of
India;
d) post- harvest storage infrastructure for agricultural produce including a
cold storages for such purposes; or
e) mechanised food grain handling system, machinery or equipment for
units processing agricultural produce as food stuff excluding alcoholic
beverages;

Services by way of construction, erection,
commissioning, or installation of original works

• “Original works” as defined in Valuation Rules means –
(a) all new constructions; or
(b) all types of additions and alterations to abandoned or damaged
structures on land that are required to make them workable,
(c) erection, commission or installation of plant, machinery or
equipment or structures, whether prefabricated or otherwise
• No service tax liability on erection or installation of machineries or
equipments for units processing agricultural produce
• Erection or installation of machineries or equipments for dal mills, rice
mills, milk dairies or cotton ginning mills -Exempt
• Only erection and construction of original works is covered
• Exemption will cover low cost houses under the scheme of affordable
housing in partnership

Temporary transfer or permitting the
use or enjoyment of a copyright
Temporary transfer or permitting the use or enjoyment of a copyright
covered under clauses (a) or (b) of sub-section (1) of section 13 of the
Indian Copyright Act, 1957 relating to original literary, dramatic, musical,
artistic works or cinematograph films;
► A music company would be required to pay service tax
► Service Tax is not payable on the royalty amount so received from the
music company by composer
► an author having copyright of a book written by him –Exempt
► copyright of a cinematographic film -Exempt

Services by a performing artist in folk or
classical art forms

Services by a performing artist in folk or classical art forms of (i) music, or
(ii) dance, or (iii) theatre, excluding services provided by such artist as a
brand ambassador;
• The service provided by any person being a performing artist in the
form of -
• folk, or
• classical
in relation to -
• music,
• dance, or
• theatre
are exempt
• if such an artist provides services as a brand ambassador for any
product, service, event or company etc for a consideration - Taxable

Services by way of collecting or providing
news

Services by way of collecting or providing news by an independent
journalist, Press Trust of India or United News of India;
• The exemption will be available to following persons or service
providers –
(a) independent journalists (individuals, reporters, correspondents
etc but not editors of newspapers or electronic media)
(b) Press Trust of India (PTI)
(c) United News of India (UNI)
• PTI and UNI are government sponsored news agencies – Non
Taxable
• News syndication by private news agencies for a consideration -
Taxable

Services by way of renting of a hotel, inn, guest
house, club, campsite or other commercial places

Services by way of renting of a hotel, inn, guest house, club, campsite or
other commercial places meant for residential or lodging purposes, having
declared tariff of a unit of accommodation below rupees one thousand per
day or equivalent

• “Declared tariff” includes charges for all amenities provided in the unit
of accommodation (given on rent for stay) like furniture, air-conditioner,
refrigerators or any other amenities, but does not include any discount
offered on the published charges for such unit

• Abatement under Notification No. 26/2012-ST is also available to such
services where declared tariff is Rs. 1000 or more and Service Tax is
payable only on 60 per cent of the gross value of taxable service

Serving of food or beverages by a
restaurant / eating joints
Services provided in relation to serving of food or beverages by a
restaurant, eating joint or a mess, other than those having (i) the facility
of air-conditioning or central air-heating in any part of the establishment,
at any time during the year, and (ii) a licence to serve alcoholic
Beverages
• It is not necessary that the facility of air-conditioning is available round
the year
• Serving of food or beverages in a centrally air-conditioned premise will
be taxed if its restaurant has a license to serve alcoholic beverages
• those restaurants which do not have license to serve alcoholic
beverages - Exempt
• Under N. No. 26/2012-ST dated 20.6.2012, abatement @ 30 per cent
is allowed w.e.f. 1.7.2012 to bundled services by way of supply of food
or any other article of human consumption or any drink in a premises,
including a hotel, convention centre, club etc. subject to condition of
non availment of Cenvat Credit on inputs.

Services by way of transportation by rail or
a vessel from one place in India to another
Services by way of transportation by rail or a vessel from one place in
India to another of the following goods -
a. petroleum and petroleum products falling under Chapter heading 2710
and 2711 of the First Schedule to the Central Excise Tariff Act, 1985
(5 of 1986);
b. relief materials meant for victims of natural or man-made disasters,
calamities, accidents or mishap;
c. defence or military equipments;
d. postal mail or mail bags;
e. household effects;
f. newspaper or magazines registered with the Registrar of Newspapers;
g. railway equipments or materials;
h. agricultural produce;
i. foodstuff including flours, tea, coffee, jaggery, sugar, milk products, salt
and edible oil, excluding alcoholic beverages; or
j. chemical fertilizer and oilcakes;

Services by way of transportation by rail or
a vessel from one place in India to another

• The exemption is in relation to –
(a) transportation of specified goods only
(b) in a rail or a vessel.
(c) from one place to other by rail or vessel

• Goods specified are of general nature, transportation of which is in
national and public interest

Services provided by a goods transport
agency for transportation of goods

Services provided by a goods transport agency by way of
transportation of -
a) fruits, vegetables, eggs, milk, food grains or pulses in a goods
carriage;
b) goods where gross amount charged for the transportation of goods
on a consignment transported in a single goods carriage does not
exceed one thousand five hundred rupees; or
c) goods, where gross amount charged for transportation of all such
goods for a single consignee in the goods carriage does not exceed
rupees seven hundred fifty;

Services by way of giving on
hire
Services by way of giving on hire -
a) to a state transport undertaking, a motor vehicle meant to carry
more than twelve passengers; or
b) to a goods transport agency, a means of transportation of goods

Exemption shall be available subject to following conditions –
• hiring to a State transport undertaking or to a goods transport
agency
• hiring of motor vehicle to carry more than 12 passengers or in
case of GTA, for transportation of goods
• In both the cases, vehicle should be given on hire

Transport of passengers with or
without accompanied belongings
Transport of passengers, with or without accompanied belongings, by -
a) air, embarking from or terminating in an airport located in the state
of Arunachal Pradesh, Assam, Manipur, Meghalaya, Mizoram,
Nagaland, Sikkim, or Tripura or at Bagdogra located in West
Bengal;
b) a contract carriage for the transportation of passengers, excluding
tourism, conducted tour, charter or hire; or
c) ropeway, cable car or aerial tramway;
The ingredients of a contract carriage are -
 It carries passengers for hire or reward
 It is engaged in contract whether expressed or implied for use of
such vehicle as a whole;
 The contract must be entered into by the person with the holder of
permit in relation to such vehicle or with any person authorized by
him

Transport of passengers with or
without accompanied belongings
 The agreed consideration can either by on time basis or one point
to another;
 The vehicle should not stop to pick up or set down passengers not
included in the contract anywhere during the journey;
 It includes maxi-cab or motor-cab.
• In cases where a bus operates on a route under a contract
carriage and passengers embark or disembark from the
bus at any place falling on the route and pay separate fares
for the whole or for stages of journey, no Service Tax
would be payable.
• transport of passenger in a contract carriage for the
transportation of passengers for tourism, conducted tour,
charter or hire is taxable

Services by way of vehicle parking to
general public
Services by way of vehicle parking to general public excluding leasing of
space to an entity for providing such parking facility
• Rent of vacant land used for parking is liable to Service
Tax
• No Service Tax is payable on providing the facility of motor
vehicle parking to general public
• Parking facility provided to any one which is not a general
public, say a bank or hotel or car dealer etc –Taxable
• General public defined to mean the body of people at large
sufficiently defined by some common quality of pubic or
impersonal nature

Services provided to Government, a local
authority or a governmental authority
Services provided to Government, a local authority or a governmental
authority by way of -
a) carrying out any activity in relation to any function ordinarily entrusted
to a municipality in relation to water supply, public health, sanitation
conservancy, solid waste management or slum improvement and
upgradation; or
b) repair or maintenance of a vessel or an aircraft
Services provided to the Government or a local authority or Governmental
Authority may cover services by way of –
(a) repair of a ship, boat or vessel or aircraft
(b) effluents and sewerage treatment;
(c) waste collection or disposal;
(d) storage, treatment or testing of water for drinking purposes; or
(e) transport of water by pipeline or conduit for drinking purposes;

Services provided to Government, a local
authority or a governmental authority

Activities carried out in relation to functions ordinarily
entrusted to municipality in relation to –
 water supply
 public health
 sanction conservation
 solid waste management
 slum improvement / upgradation

Services of general insurance
business
Services of general insurance business provided under
following schemes
a. Hut Insurance Scheme;
b. Cattle Insurance under Swarnajaynti Gram Swarozgar
Yojna (earlier known as Integrated Rural Development
Programme);
c. Scheme for Insurance of Tribals;
d. Janata Personal Accident Policy and Gramin Accident
Policy;
e. Group Personal Accident Policy for Self-Employed Women;
f. Agricultural Pumpset and Failed Well Insurance;
g. premia collected on export credit insurance;

Services of general insurance
business
h. Weather Based Crop Insurance Scheme or the Modified
National Agricultural Insurance Scheme, approved by the
Government of India and implemented by the Ministry of
Agriculture;
i. Jan Arogya Bima Policy;
j. National Agricultural Insurance Scheme (Rashtriya Krishi
Bima Yojana);
k. Pilot Scheme on Seed Crop Insurance;
l. Central Sector Scheme on Cattle Insurance;
m. Universal Health Insurance Scheme;
n. Rashtriya Swasthya Bima Yojana; or
o. Coconut Palm Insurance Scheme;

Services provided by an incubatee
Services provided by an incubatee up to a total turnover of fifty lakh
rupees in a financial year subject to the following conditions, namely:-
a) the total turnover had not exceeded fifty lakh rupees during the
preceding financial year; and
b) a period of three years has not been elapsed from the date of
entering into an agreement as an incubatee

Services provided by an incubatee up to a total business
turnover of fifty lakh rupees in a financial year subject to
conditions
• the total business turnover had not exceeded fifty lakh
rupees during the preceding financial year; and
• a period of three years has not lapsed from the date of
entering into an agreement as an incubatee

Service by an unincorporated body or a
non- profit entity
Service by an unincorporated body or a non- profit entity registered under
any law for the time being in force, to its own members by way of
reimbursement of charges or share of contribution -
a) as a trade union;
b) for the provision of carrying out any activity which is exempt from
the levy of service tax; or
c) up to an amount of five thousand rupees per month per member
for sourcing of goods or services from a third person for the
common use of its members in a housing society or a residential
complex
• Services should be provided to own members and not to non-
members.
• Service of an unincorporated body or a non- profit entity registered
under any law for the time being in force to its own members up to an
amount of Rs 5,000 per member per month by way of reimbursement
of charges or share of contribution is exempt from service tax

Services provided by
Intermediaries
Services by the following persons in respective capacities -
a) sub-broker or an authorised person to a stock broker;
b) authorised person to a member of a commodity exchange;
c) mutual fund agent to a mutual fund or asset management company;
d) distributor to a mutual fund or asset management company;
e) selling or marketing agent of lottery tickets to a distributer or a selling
agent;
f) selling agent or a distributer of SIM cards or recharge coupon
vouchers;
g) business facilitator or a business correspondent to a banking company
or an insurance company, in a rural area; or
h) sub-contractor providing services by way of works contract to another
contractor providing works contract services which are exempt;

Services by an organizer to any person in respect

of a business exhibition held outside India

Services by an organizer to any person in respect of a business exhibition
held outside India

► Organizer should be in India
► Exhibition should be held outside India
► It should be in relation to business

Services by way of making telephone calls

Services by way of making telephone calls from -
a) departmentally run public telephone;
b) guaranteed public telephone operating only for local calls; or
c) free telephone at airport and hospital where no bills are being issued

Services by way of slaughtering of bovine
animals

Services by way of slaughtering of bovine animals

Services received from a provider of
service located in a non- taxable territory
Services received from a provider of service located in a non- taxable
territory by -
a) Government, a local authority, a governmental authority or an
individual in relation to any purpose other than commerce, industry
or any other business or profession;
b) an entity registered under section 12AA of the Income tax Act, 1961
(43 of 1961) for the purposes of providing charitable activities; or
c) a person located in a non-taxable territory
• If services are used for industry, business or commercial purpose,
service tax is payable under reverse charge basis
• Other purposes, it will be exempt from service tax

Services of Public Libraries

Services of public libraries by way of lending of books, publications or any
other knowledge- enhancing content or material

Following services of public libraries shall be exempt –
► lending of books
► lending of publications
► lending of other knowledge enhancing content or
material, (i.e. in soft or hard version, digital content,
web content etc)
• ‘Public library’ has not been defined

Services by Employees’ State Insurance
Corporation to persons governed under the
Employees Insurance Act, 1948
Services by Employees’ State Insurance Corporation to persons
governed
under the Employees’ Insurance Act, 1948 (34 of 1948)

► Covers the services provided by the Employee’s State Insurance
Corporation (ESIC) constituted under the Employees State Insurance
Act, 1948
► in relation to employee’s sickness, maternity and employment injury
and promotion of measures for health etc of insured persons

Services by way of transfer of a going
concern

Services by way of transfer of a going concern, as a whole or an
independent part thereof

► Going Concern as per AS-1
► Sale of business as a whole
► Related services are taxable

Services by a governmental authority by way of any activity

in relation to any function entrusted to a municipality

Services by a governmental authority by way of any activity in relation to
any function entrusted to a municipality under article 243 W of the
Constitution

► All services are not exempt
► Services by a governmental authority by way of any activity in relation
to any function entrusted to a municipality under article 243W of the
Constitution are exempt

A Knowledge Workshop-Presentation II dated 14th July,2012

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