https://www.taxtmi.com/caselaws?id=784400 Service tax classification depends on the substance of contractual obligations read as a whole, not merely on on-site personnel deployment or manpower-linked billing. Software support, development, testing, maintenance and related technical deliverables were treated as software and IT services rather than manpower supply; the activity was therefore not taxable under manpower supply for the pre-16 May 2008 period. Travel, conveyance, meal and visa reimbursements were not consideration for the underlying service and could not be included in taxable value under Section 67 through Rule 5. The tax demand and consequential penalty were set aside. en-us Thu, 04 Dec 2025 00:00:00 +0530 Mon, 05 Jan 2026 08:04:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784400 Service tax classification depends on the substance of contractual obligations read as a whole, not merely on on-site personnel deployment or manpower-linked billing. Software support, development, testing, maintenance and related technical deliverables were treated as software and IT services rather than manpower supply; the activity was therefore not taxable under manpower supply for the pre-16 May 2008 period. Travel, conveyance, meal and visa reimbursements were not consideration for the underlying service and could not be included in taxable value under Section 67 through Rule 5. The tax demand and consequential penalty were set aside. Case-Laws Service Tax Thu, 04 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784400