https://www.taxtmi.com/caselaws?id=763094 Deputation of employees to a subsidiary was treated as manpower recruitment or supply agency service under the pre-2012 definition, because the arrangement showed secondment, operational control with the subsidiary, possible return of employees, and recovery of salary and allowances with markup. Applying substance over form, the transfer was not a mere reimbursement and amounted to taxable manpower supply for consideration. As the service tax was correctly paid, the refund claim failed. The objections based on recovery of tax from the subsidiary and the alternative claim for refund of interest did not change the result. en-us Wed, 11 Dec 2024 00:00:00 +0530 Thu, 12 Dec 2024 11:44:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763094 Deputation of employees to a subsidiary was treated as manpower recruitment or supply agency service under the pre-2012 definition, because the arrangement showed secondment, operational control with the subsidiary, possible return of employees, and recovery of salary and allowances with markup. Applying substance over form, the transfer was not a mere reimbursement and amounted to taxable manpower supply for consideration. As the service tax was correctly paid, the refund claim failed. The objections based on recovery of tax from the subsidiary and the alternative claim for refund of interest did not change the result. Case-Laws Service Tax Wed, 11 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763094