Notional Interest on Deposit Not Taxable | CESTAT

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Notional interest Security deposit Taxable service value CESTAT ruling Service tax valuation
Case Details: Jyotsna Vaults Versus Commissioner of CGST & Central Excise, Jaipur I (2025) 32 Centax 295 (Tri.-Del) 

Judiciary and Counsel Details

  • Ms. Binu Tamta, Member (J) andMs. Hemambika R. Priya, Member (T)
  • Ms. Neha Somani, Chartered Accountant for the Appellant.
  • Shri Anand Narayan, Authorised Representative for the Respondent.

Facts of the Case

The Appellant was paying service tax on the rental amount of the property. The issue in dispute was whether notional interest earned on security deposits received from service recipients could be subjected to service tax. The matter pertained solely to the inclusion of such notional interest in the valuation of taxable services under the service tax law. The matter was accordingly placed before the CESTAT. 

 

CESTAT Held 

 The CESTAT held that no service tax could be levied on notional interest earned on security deposits received from service recipients. Referring to precedents, the Tribunal concluded that such notional income does not fall within the value of taxable service under section 67 of the Finance Act, 1994. The impugned order was set aside. 

 

List of Cases Cited

Murli Realtors Pvt. Ltd. v. Commissioner — 2015 (37) S.T.R. 618 (Tri. Mumbai) — Followed [Paras 4, 5]

 

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