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of The CESTAT held that the appellant's arrangement with manpower agencies qualifies under Rule 5(2) of the Service Tax (Determination of Value) Rules, 2006, as the agencies acted as 'pure agents' disbursing wages without markup and charging only supervision fees. Consequently, salary payments made through these agencies are excluded from taxable value under the Reverse Charge Mechanism. The tribunal found no suppression of facts or intent to evade tax, noting accurate filing of ST-3 returns and proper accounting. Therefore, the extended limitation period and penalty were not applicable. The service tax demand and penalty were set aside, and the appeal was allowed.
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