https://www.taxtmi.com/caselaws?id=239121 CESTAT Mumbai held that service tax on reverse charge basis under section 65(105)(k) of the Finance Act, 1994, was not applicable as there was no supply of manpower or recruitment service by the foreign holding company to the appellant. The global employees were found to be directly employed by the appellant, establishing an employee-employer relationship. The payment of a portion of their salary through the foreign holding company did not amount to a supply of manpower services. The method of salary disbursement was held irrelevant to the nature of the transaction. The order imposing service tax was set aside, and the decision was in favor of the appellant. en-us Mon, 30 Sep 2013 00:00:00 +0530 Fri, 01 Aug 2025 12:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239121 CESTAT Mumbai held that service tax on reverse charge basis under section 65(105)(k) of the Finance Act, 1994, was not applicable as there was no supply of manpower or recruitment service by the foreign holding company to the appellant. The global employees were found to be directly employed by the appellant, establishing an employee-employer relationship. The payment of a portion of their salary through the foreign holding company did not amount to a supply of manpower services. The method of salary disbursement was held irrelevant to the nature of the transaction. The order imposing service tax was set aside, and the decision was in favor of the appellant. Case-Laws Service Tax Mon, 30 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239121