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    <title>2026 (4) TMI 1589 - CESTAT BANGALORE</title>
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    <description>Seconded employees placed under the host entity&#039;s operational control for its Indian business, while remaining on the overseas parent&#039;s payroll and with salary costs reimbursed, may constitute manpower recruitment or supply service for service tax purposes under reverse charge. On the facts described, the arrangement was treated as a taxable manpower supply rather than a mere reimbursement of employment costs. The demand was confined to the normal period because no mala fide intention was found, so the extended period was not invoked. Penalties were also deleted, leaving the service tax demand sustained only for the normal period.</description>
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    <pubDate>Fri, 24 Apr 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=790520</link>
      <description>Seconded employees placed under the host entity&#039;s operational control for its Indian business, while remaining on the overseas parent&#039;s payroll and with salary costs reimbursed, may constitute manpower recruitment or supply service for service tax purposes under reverse charge. On the facts described, the arrangement was treated as a taxable manpower supply rather than a mere reimbursement of employment costs. The demand was confined to the normal period because no mala fide intention was found, so the extended period was not invoked. Penalties were also deleted, leaving the service tax demand sustained only for the normal period.</description>
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      <pubDate>Fri, 24 Apr 2026 00:00:00 +0530</pubDate>
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