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    <title>2009 (2) TMI 709 - COMMISSIONER OF CENTRAL EXCISE (APPEALS),  PUNE-II</title>
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    <description>Leasing a running industrial unit with its permanent employees to another operator, where the employees continued the same manufacturing activity under the lessee&#039;s supervision, did not amount to manpower recruitment and supply agency service. The receipts were salary-related reimbursements and related deductions handled on behalf of the employees, not consideration for supplying manpower as an independent taxable service. On that basis, the service tax demand was unsustainable, and the connected interest and penalties also failed because they rested on the same incorrect characterisation of the arrangement.</description>
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      <description>Leasing a running industrial unit with its permanent employees to another operator, where the employees continued the same manufacturing activity under the lessee&#039;s supervision, did not amount to manpower recruitment and supply agency service. The receipts were salary-related reimbursements and related deductions handled on behalf of the employees, not consideration for supplying manpower as an independent taxable service. On that basis, the service tax demand was unsustainable, and the connected interest and penalties also failed because they rested on the same incorrect characterisation of the arrangement.</description>
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