Manpower supply by a co-operative society was held taxable, as society status did not exclude service tax liability.

A co-operative society supplying manpower under contract was treated as providing taxable manpower recruitment or supply agency service because the workers remained on its rolls, the service was rendered for consideration, and the society discharged the relevant statutory obligations. Its status as a society or non-commercial concern did not exempt it from service tax, since a registered society is an association of persons and a juristic person within the taxable meaning of "person." The contract's allocation of tax responsibility to the society also did not displace statutory liability. The demand was sustained and the appeal failed.

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Issues: Whether a co-operative society supplying manpower under contract was liable to service tax as a manpower recruitment or supply agency, and whether its status as a society or non-commercial concern exempted it from tax.

Analysis: The service rendered consisted of supplying manpower to the client for consideration, with the workers remaining on the society's rolls and statutory obligations being discharged by the society. The statutory definition of taxable service covered manpower recruitment or supply agency service. A society is an association of persons and, being a registered body and juristic person, falls within the meaning of "person" for taxation under the relevant statutory framework. The contract terms also placed responsibility for taxes on the society, and that contractual allocation did not alter the statutory liability.

Conclusion: The society was liable to pay service tax on the manpower supply services and the demand was sustained; the appeal failed.

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