https://www.taxtmi.com/caselaws?id=467478 The note addresses two issues: first, whether supplying trained personnel by one joint-venture partner to the other constitutes taxable manpower recruitment or supply agency service; applying the secondment/deputation test the author concludes such supply can attract tax even where salaries are reimbursed without separate markup, and no contractual mandate to supply personnel was found. Second, whether the demand is time-barred; the author concludes the extended limitation cannot be invoked absent proof of suppression with intent, so part of the demand is time-barred and the matter is remanded for verification for the normal period without penalties. 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 The note addresses two issues: first, whether supplying trained personnel by one joint-venture partner to the other constitutes taxable manpower recruitment or supply agency service; applying the secondment/deputation test the author concludes such supply can attract tax even where salaries are reimbursed without separate markup, and no contractual mandate to supply personnel was found. Second, whether the demand is time-barred; the author concludes the extended limitation cannot be invoked absent proof of suppression with intent, so part of the demand is time-barred and the matter is remanded for verification for the normal period without penalties. Case-Laws Service Tax Thu, 30 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467478