CESTAT allowed the appeal and set aside the impugned orders. It...

CESTAT allowed the appeal and set aside the impugned orders. It held the overseas entities to be the expats' employers and that their transfer to the appellant constitutes supply of manpower services; however, invocation of the extended period of limitation by Revenue was unjustified as the appellant's contrary view was debatable and there was no wilful suppression. Demands for service tax on remuneration paid to the appellant's directors were held unsustainable and quashed. Crucially, the appellant, being an SEZ unit, was entitled to upfront and complete exemption under the SEZ statutory regime for services procured for authorised operations, thereby negating any service tax liability for the manpower services.