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    <title>2026 (4) TMI 1080 - CESTAT CHENNAI</title>
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    <description>Output-oriented work arrangements with remuneration linked to production, labour remaining under the contractor&#039;s control, and statutory compliance obligations resting on the contractor were treated as a contract for service, not manpower recruitment or supply agency service. Applying the control test, mode of remuneration test, integration test and the broader multifactor approach, the tribunal found that the activity was job work for specified hot rolled products and not supply of manpower. It also accepted that restructuring the business to reduce tax liability was legitimate tax mitigation, as no sham, fraud or fraudulent device was proved. The service tax demands, interest and penalties were therefore unsustainable.</description>
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