2024 (8) TMI 986

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....gned show-cause notice dated 26.09.2023 issued by respondent no.4 at Annexure-A demanding IGST of Rs. 59,57,19,228/- along with interest and penalty. 2. The petitioner has also sought for declaration that payment of salary made to expats by the petitioner does not attract IGST as the same does not amount to manpower and recruitment supply of services from the overseas group entities to the petitioner. 3. The learned counsel for petitioner would point out that the petitioner is engaged in the business of designing, manufacturing, supplying, installing and commissioning of goods relating to railways and metro projects and during the period from July, 2017 and March, 2023 employees of overseas group entities (expats) were on the payroll ....

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....se notice being dropped to that extent. 8. Sri. K. Hema Kumar, learned AGA submits that the purport of Circular needs to be examined in the facts of the case and even otherwise, the applicability of the Circular requires adjudication and accordingly the matter may be relegated back to the stage of reply to the show-cause notice. 9. After hearing the matter and noticing the contention raised by the petitioner as referred to above, it must be noticed that Circular dated 26.06.2024 referred to above may have bearing on the stand of the petitioner insofar as show-cause notice is concerned. Para 3.6 to Para 4 of Circular dated 26.06.2024 reads as hereunder: "3.6 In case of import of services by a registered person in India from a ....