Scope of Job Work and Manpower supply services - Applicability of service tax on the services received by apparel exporters in relation to fabrication of garments

Job work vs manpower supply: classification determines whether services to apparel exporters attract service tax.

Classification between manpower supply and job work depends on contractual terms and factual scope: manpower supply places personnel under recipient control with charges tied to deployed labour, while job work assigns a specific fabrication task with provider accountability and per-piece valuation. Service tax exemption under the negative list applies only where the job work involves a process subject to excise duties. Determination of tax liability requires case-by-case examination of control, payment basis, accountability, place of work, and related contractual terms.