2025 (6) TMI 1174

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....r Recruitment Agency and Supply Service'. For providing such taxable service, the appellants got themselves registered with the service tax department. During the disputed period, the service tax department had compared the figures/data reflected in the TDS certificate(s)/Form No. 26AS vis-à-vis those reflected in the ST-3 Returns filed by the appellants. On comparison between the figures reflected in the said documents, it was observed by the department that as per Form No. 26AS, the appellants had short-paid service tax and accordingly, proceedings were initiated against the appellants, seeking for confirmation of the service tax demand. The matter arising out of the Show Cause Notice (SCN) dated 16.10.2015 was adjudicated vide the....

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....e to the appellants for non-prosecution in respect of the dispute arising out of the present case. On merits, the appellants have contended that the activity provided by the appellants to their clients should appropriately be classifiable under the Manpower Recruitment Agency and Supply Service and demands confirmed in the impugned order, holding such service as 'Storage and Warehousing' and 'Cleaning Service' should not be the defensible ground for confirmation of the adjudged demands. 4. On reading of the reply to the SCN dated 08.03.2016 annexed to the appeal memorandum, we find that the appellants had claimed that they had already paid the service tax amounting to Rs.1,26,42,082/- before issuance of the SCN in respect of the Manpower....