2014 (1) TMI 145

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....a, Advocates, for the Appellant. Shri Amresh Jain, DR, for the Respondent. ORDER The appellant is a subsidiary company of Daifuku Company Ltd., Japan. The parent company sent a few of their employees to the appellant-company for managing the affairs of the appellant-company. Revenue wants to tax payments made to the said staff through the parent company in Japan, considering the service a....

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....oyee relationship exists and the person utilising the service, there is no service of manpower supply. He also submits that their parent company is not professionally engaged in the supply of manpower and that company will not get covered by the ordinary meaning of 'manpower supply agency'. 3. Ld. DR appearing for the Revenue relies on the decision of the Tribunal in the case of Carborandu....