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CESTAT determined services provided under "Time and Material Projects" constituted Manpower Recruitment and Supply Agency Service, not Consulting Engineer Service, following precedent established in similar Philips Electronics India agreements. Service tax demand upheld as manpower supply service. The appellant's ST-3 returns declared services as exempt under Consulting Engineer Service until 16.05.2008, reflecting bona fide interpretation rather than willful suppression. Extended limitation period found inapplicable. Tribunal modified order confirming demand for normal period, maintained penalties under Sections 76 and 77, but set aside Section 78 penalty due to absence of deliberate mis-declaration. Appeal partially allowed.
CESTAT determined services provided under "Time and Material Projects" constituted Manpower Recruitment and Supply Agency Service, not Consulting Engineer Service, following precedent established in similar Philips Electronics India agreements. Service tax demand upheld as manpower supply service. The appellant's ST-3 returns declared services as exempt under Consulting Engineer Service until 16.05.2008, reflecting bona fide interpretation rather than willful suppression. Extended limitation period found inapplicable. Tribunal modified order confirming demand for normal period, maintained penalties under Sections 76 and 77, but set aside Section 78 penalty due to absence of deliberate mis-declaration. Appeal partially allowed.
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