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    <description>Rule 33 pure-agent exclusion was unavailable where the supplier had entered into employment arrangements with the workmen, maintained wage records, and remained legally liable for their salary and wages. Authorisation by the client and separate invoice disclosure did not alter the underlying liability, because the amounts were paid in the supplier&#039;s own capacity rather than on behalf of the recipient. As a result, the salary and wages formed part of the consideration for manpower supply and could not be excluded from the value of supply under Section 15 of the CGST Act.</description>
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