https://www.taxtmi.com/caselaws?id=798268 Employee secondment from an overseas group company to its Indian group entity may constitute taxable manpower recruitment or supply agency service under reverse charge where the overseas entity retains the employment relationship, pays salaries, maintains employment terms and reabsorbs the secondees after secondment. Indian operational control and reimbursement of employment costs without markup do not negate manpower supply. Extended limitation for service-tax recovery requires fraud, collusion, wilful misstatement, suppression, or contravention with intent to evade tax. Recorded expenses, banking-channel remittances and conflicting views on taxability do not establish wilful suppression; consequently, a demand wholly beyond normal limitation is time-barred, with interest and penalties not recoverable. en-us Wed, 02 Sep 2026 00:00:00 +0530 Fri, 04 Sep 2026 08:24:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798268 Employee secondment from an overseas group company to its Indian group entity may constitute taxable manpower recruitment or supply agency service under reverse charge where the overseas entity retains the employment relationship, pays salaries, maintains employment terms and reabsorbs the secondees after secondment. Indian operational control and reimbursement of employment costs without markup do not negate manpower supply. Extended limitation for service-tax recovery requires fraud, collusion, wilful misstatement, suppression, or contravention with intent to evade tax. Recorded expenses, banking-channel remittances and conflicting views on taxability do not establish wilful suppression; consequently, a demand wholly beyond normal limitation is time-barred, with interest and penalties not recoverable. Case-Laws Service Tax Wed, 02 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798268