https://www.taxtmi.com/caselaws?id=802084 Foreign-group secondment arrangements are taxable under reverse charge where contractual terms retain the foreign entity's substantive employment nexus, even if the Indian entity pays salaries, directs daily work and receives personnel without a mark-up. Temporary assignments preserving foreign employment, salary reference, social-security, pension and termination arrangements amount to foreign manpower supply before 1 July 2012 and taxable services thereafter. Reverse-charge liability remains payable in cash despite revenue neutrality. However, an interpretative dispute and absence of deliberate suppression prevent use of the extended limitation period and penalties; recovery is confined to the normal period, excluding time-barred pre-July 2012 liability, subject to verification and re-quantification. en-us Thu, 29 Oct 2026 00:00:00 +0530 Sat, 31 Oct 2026 08:32:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802084 Foreign-group secondment arrangements are taxable under reverse charge where contractual terms retain the foreign entity's substantive employment nexus, even if the Indian entity pays salaries, directs daily work and receives personnel without a mark-up. Temporary assignments preserving foreign employment, salary reference, social-security, pension and termination arrangements amount to foreign manpower supply before 1 July 2012 and taxable services thereafter. Reverse-charge liability remains payable in cash despite revenue neutrality. However, an interpretative dispute and absence of deliberate suppression prevent use of the extended limitation period and penalties; recovery is confined to the normal period, excluding time-barred pre-July 2012 liability, subject to verification and re-quantification. Case-Laws Service Tax Thu, 29 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802084