https://www.taxtmi.com/caselaws?id=467478 Secondment or deputation of trained personnel may fall within manpower recruitment or supply agency service where one entity provides personnel to another, even if the recipient reimburses salary without a separate markup. The absence of a contractual obligation to supply personnel does not by itself prevent taxability. Extended limitation under the Finance Act, 1994 requires proof of suppression with intent to evade tax or other clear statutory grounds; prior disclosures, available records and genuine interpretative uncertainty may defeat its invocation. Taxability may therefore apply for the normal period, subject to verification of receipts, while penalties need not be imposed for the remanded period. en-us Thu, 30 Mar 2023 00:00:00 +0530 Fri, 20 Mar 2026 11:49:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467478 Secondment or deputation of trained personnel may fall within manpower recruitment or supply agency service where one entity provides personnel to another, even if the recipient reimburses salary without a separate markup. The absence of a contractual obligation to supply personnel does not by itself prevent taxability. Extended limitation under the Finance Act, 1994 requires proof of suppression with intent to evade tax or other clear statutory grounds; prior disclosures, available records and genuine interpretative uncertainty may defeat its invocation. Taxability may therefore apply for the normal period, subject to verification of receipts, while penalties need not be imposed for the remanded period. Case-Laws Service Tax Thu, 30 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467478