Taxability of employee deputation and extended limitation under service tax and post-2012 regime remain in dispute.

The dispute concerns whether deputation of employees by overseas entities to the petitioner during April 2008 to March 2013 was taxable as employer-agreement or supply agency service, or as a service under the post-1 July 2012 regime, and whether the extended limitation period could be used for recovery. The Supreme Court condoned delay, issued notice returnable in four weeks, and permitted dasti service.

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Issues: Whether the deputation of employees by overseas entities to the petitioner during April 2008 to March 2013 was taxable as employer agreement and supply agency service or as a service under the post-1 July 2012 regime, and whether the extended period of limitation could be invoked for recovery.

Outcome: Delay condoned. Notice issued returnable in four weeks. Dasti service permitted.

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