https://www.taxtmi.com/caselaws?id=467000 A consolidated contractual consideration for imported manpower/secondment services that permits or requires a split mode of payment includes payments made directly in India to secondees within the gross amount charged under Section 67; contractual terms (salary structure, supplier discretion, reimbursement obligation, payroll retention) establish the requisite nexus for valuation, and such amounts are taxable. However, penalties were not sustainable because no suppression with intent to evade was found, and invocation of the extended limitation period was improper given the absence of deliberate concealment and the unsettled legal position; the demand is therefore confined to the normal limitation period and tax attributable to TDS is to be adjusted. en-us Tue, 07 Nov 2023 00:00:00 +0530 Sat, 28 Feb 2026 12:53:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467000 A consolidated contractual consideration for imported manpower/secondment services that permits or requires a split mode of payment includes payments made directly in India to secondees within the gross amount charged under Section 67; contractual terms (salary structure, supplier discretion, reimbursement obligation, payroll retention) establish the requisite nexus for valuation, and such amounts are taxable. However, penalties were not sustainable because no suppression with intent to evade was found, and invocation of the extended limitation period was improper given the absence of deliberate concealment and the unsettled legal position; the demand is therefore confined to the normal limitation period and tax attributable to TDS is to be adjusted. Case-Laws Service Tax Tue, 07 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467000