TaxTMI 
TaxTMI 
2016 (2) TMI 689
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....nt or Supply Agency Services'. Appellants herein under the contract with sugar factories had extended the services of cutting and transporting of sugarcane to the sugar factories and their job included planning, arranging, authorization and nomination of persons who would be engaged in the said work. Revenue authorities are of the view that the said activity would fall under the category of "Manpower Recruitment or Supply Agency Services", as the appellants had provided the manpower for cutting and transporting of sugarcane. We find that both the lower authorities had erred in coming to such conclusion as on perusal of the agreement entered by the representative of the individuals with the sugar factories, it is noticed that the individ....
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....our intensive activity. Very soon, this work would be done mechanically. So, the nature of work undertaken by the respondent must be understood in the context in which it was understood by the respondent and its principal-sugar factory . This interpretation of the agreement between the respondent and its principal is in tune with the Judgment of the Supreme Court in the case of Super Poly Fabriks Ltd. Vs. Commissioner of C. Ex., Punjab, reported in 2008 (10) S.T.R . 545 (S.C.) . Paragraph No. 8 of the said judgment can be relied upon to drag the point home, which reads as under :- "8. There cannot be any doubt whatsoever that a document has to be read as a whole. The purport and object with which the parties thereto entered into a contra....