https://www.taxtmi.com/caselaws?id=787195 Classification: agreements, invoices and deployment records show personnel supplied and working under recipient control, so the service is manpower recruitment/supply agency service (classification upheld for the assessee). Extended limitation: earlier audit and Audit Memo put the Department on notice of the issue, so invocation of the proviso to extend limitation is unsustainable and the extended-period demand is set aside. Normal period: records and invoices show amounts billed to a body corporate recipient; applying Rule placing liability on recipient, the tax for the normal period is sustained but payable by the service recipient, not the appellant. Penalty: no evidence of suppression with intent; penalty under Section 78 set aside. en-us Thu, 26 Feb 2026 00:00:00 +0530 Sat, 28 Feb 2026 08:41:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787195 Classification: agreements, invoices and deployment records show personnel supplied and working under recipient control, so the service is manpower recruitment/supply agency service (classification upheld for the assessee). Extended limitation: earlier audit and Audit Memo put the Department on notice of the issue, so invocation of the proviso to extend limitation is unsustainable and the extended-period demand is set aside. Normal period: records and invoices show amounts billed to a body corporate recipient; applying Rule placing liability on recipient, the tax for the normal period is sustained but payable by the service recipient, not the appellant. Penalty: no evidence of suppression with intent; penalty under Section 78 set aside. Case-Laws Service Tax Thu, 26 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787195