In Brief
HGOs and PTOs (private tour operators) providing Haj pilgrimage packages are liable to pay service tax. Although services are rendered to facilitate religious pilgrimage, the exemption under the 'conduct of any religious ceremony' does not apply because HGOs arrange travel and accommodation but do not themselves conduct the religious ceremonies. The exemption for specified organisations applies only to the Haj Committee (a statutory body), not to private operators. The distinction is not discriminatory as Haj Committees are government-controlled, statutory bodies without profit motive, whereas HGOs are commercial operators. Services are taxable as they are provided in India by providers based in India to recipients ordinarily resident in India.
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