Security personnel v/s manpower supply

[Ashok Chopra]

Will security personnel depoloyed  by security agency at the unit  be considered as "SUPPLY OF MANPOWER FOR ANY PURPOSE" and does it become our liability to pay 75% Service Tax on secutiy agency bill as per Notification No. 30/2012-ST dated 20-06-2012 because in the bill raised by security agency clearly shows number of duties by security guards and security supervisors at our unit.

Please advice accordingly

AI Summary

Reverse charge on manpower supply: security agency services may attract reverse charge when personnel are deployed under recipient's control.
Whether services by a security agency are Supply of Manpower depends on contract character and control: if the agency provides security and retains operational control, it is a security service and not manpower supply; if personnel are hired and deployed under the recipient's supervision, it is supply of manpower and reverse charge applies. The notification regime was amended to include security services when statutory conditions are satisfied.