2017 (11) TMI 350

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....ndent ORDER Per: Ramesh Nair This appeal is directed against Order-in-Original No.03/ST/2012 dated 6-8-2012 passed by the Commissioner of Central Excise, Customs & Service Tax, Nashik, whereby demand of Service Tax amounting to Rs. 82,05,655/- under the category of Manpower Recruitment and Supply Agency was confirmed, also demanded interest under Section 75 and imposed penalty under Secti....

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.... said decision it was held that Manpower deputed to the group companies is not provision of service, hence the same is not liable for service tax. During the argument of the counsel, bench has asked to submit share holding pattern of all the group companies to whom the appellant have deputed their manpower. The appellant filed letter dated 30-7-2017 and submitted share holding pattern of all the g....

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....e term "Group Company", it cannot be concluded whether company is group company or otherwise. Share holding pattern submitted by the appellant is reproduced below: From above share holding pattern, it is observed that in some companies share holding is less than 50%, therefore it cannot be said that these are subsidiaries of the appellant. Similarly in other subsidiary companies it has to be as....