Dear All,

Could anyone tell about the Service tax implication on the following transaction?

X is a Project Office renders services, under the category of Mining of Mineral or Oil & Gas services, to an Indian entity, which charges service tax on their invoices.
Apart from above PO receives certain services for example repair & maintenance for drilling rig from the overseas vendor.

1. The Purchase order will be placed by Head office located at Europe.
2. Invoice will be raised on HO.
3. HO at Europe will make payment to the overseas service provider.
4. The aforementioned costs will be passed to Project Office by way of Debit Note.
5. There won’t be any physical payment by PO to HO(Just book entry which get nullified while consolidation)

My query is whether service tax would attract under revers charge for the cost allocation to the project by considering the following rules.

A. Place of provision of service rules. (Defines HO and BO are distinct and not the project office)
B. Erstwhile Import of service rules, 2006 (Sec.66A also defines the BO and not the project office)

Thank & Regards,
R Sridhar
Manager-Finance.

My CA wants to sign the following letter after audit.



DECLARATION OF COMPLETION OF AUDIT AND AUDIT FORMALITIES

We the under named artices of ……………. have conducted the Audit as per the Standards laid down by office to the highest standards and all the material facts has been reported to the Principal and also recorded in the working papers. The Details of all the claims taken by the party as per the prevailing laws in India .That we have prepared all the Peer review Papers in the audit and no part is pending. If any gross negligence is found,we may be hold personally liable for the same.

Name of the Unit;
Period :
Staff Involved:

Final Checking of BS ,P& L etc. etc by :
Final Checking of Form 3CD to be Uploaded by:


( ) ( )
Articled Clerk Articled Clerk


Pls suggest me should I sign or not.

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