https://www.taxtmi.com/caselaws?id=245634 The HC held that deputation of employees by a company to its group subsidiaries does not constitute Manpower Supply Recruitment Agency Service liable to service tax. The respondent merely reimbursed actual employee costs without profit, maintained control and supervision over the deputed staff, and was not engaged in a commercial activity of supplying manpower to clients. The subsidiaries were not clients, and no agency-client relationship existed. The definition of Manpower Supply Recruitment Agency Service, though broad, requires the entity to be commercially engaged in providing manpower supply services to clients, which was absent here. The court ruled in favor of the respondent, dismissing the Revenue's claim. en-us Thu, 20 Mar 2014 00:00:00 +0530 Tue, 29 Jul 2025 14:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245634 The HC held that deputation of employees by a company to its group subsidiaries does not constitute Manpower Supply Recruitment Agency Service liable to service tax. The respondent merely reimbursed actual employee costs without profit, maintained control and supervision over the deputed staff, and was not engaged in a commercial activity of supplying manpower to clients. The subsidiaries were not clients, and no agency-client relationship existed. The definition of Manpower Supply Recruitment Agency Service, though broad, requires the entity to be commercially engaged in providing manpower supply services to clients, which was absent here. The court ruled in favor of the respondent, dismissing the Revenue's claim. Case-Laws Service Tax Thu, 20 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245634