2012 (11) TMI 975

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....;   K.S. Ravi Shankar and N. Anand for the Appellant. Ganesh Havanur for the Respondent. ORDER M. Veeraiyan, Technical Member - Heard both sides on the stay petitions. 2.1 In the case dealt with in appeal No.ST/1488/2010, there is a total demand of around Rs.3.65 crores on two counts, one of Rs.1.82 crores under the category of "Manpower Recruitment & Supply Agency Service" and other r....

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....were working directly under Project Managers appointed by the appellant. The 'intellectual property right' on the software so developed is with the appellant and that the same may be specifically assigned to the clients in certain cases. In such a situation, the activities cannot be treated as relating to 'supply of manpower'. In this regard, he relies on the Stay Order No. 1391/2011, dated 15.12.....

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....ce' are not justified. 3.2 As regards the demand of about Rs. 60 lakhs on reimbursable expenses relating to employees deputed to USA, he submits that the same relates to activities undertaken entirely at places 'outside India' and therefore, the question of demand of service tax does not arise. 4. The learned Additional Commissioner (AR) reiterates the finding and reasoning of the Commissioner. ....