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    <description>Activities carried out inside the factory on a lump-sum job contract, including cutting, punching, drilling and bending of material supplied by the recipient, were part of the manufacturing process before the RG-1 stage and not manpower recruitment or supply agency service. The contract was treated as execution of work rather than supply of labour, and the recipient&#039;s description as principal employer did not change the true nature of the arrangement. The exemption and coverage considered under Notification No. 8/2005-ST also supported non-taxability, and taxing the same value again was viewed as impermissible double taxation. The service tax demand was therefore unsustainable.</description>
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