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CESTAT dismissed the revenue's appeal and affirmed the impugned order, thereby dropping the demand for service tax for the post-negative list period 1.7.2012-31.3.2015 in respect of "manpower supply service" allegedly provided by an overseas group entity to its Indian group company. The Tribunal held that the transactions constituted deputation/secondment of employees to execute the overseas principal's own contract and did not amount to supply of manpower by an agency; thus no taxable manpower recruitment or supply service arose. The CESTAT distinguished contrary apex court authority on facts and relied on prior tribunal and HC reasoning; the revenue's challenge was dismissed.
CESTAT dismissed the revenue's appeal and affirmed the impugned order, thereby dropping the demand for service tax for the post-negative list period 1.7.2012-31.3.2015 in respect of "manpower supply service" allegedly provided by an overseas group entity to its Indian group company. The Tribunal held that the transactions constituted deputation/secondment of employees to execute the overseas principal's own contract and did not amount to supply of manpower by an agency; thus no taxable manpower recruitment or supply service arose. The CESTAT distinguished contrary apex court authority on facts and relied on prior tribunal and HC reasoning; the revenue's challenge was dismissed.
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