Overseas manpower recruitment services trigger reverse charge liability under sections 65(105)K and 65B(44) despite revenue neutrality claims

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....CESTAT upheld service tax liability on appellant as recipient of manpower recruitment and supply services from overseas entity, following Supreme Court precedent in Northern Operating Systems case. The tribunal determined that foreign company provided taxable services under Finance Act sections 65(105)K (pre-2012) and 65B(44) (post-2012), making appellant liable under reverse charge mechanism per section 66A. However, CESTAT rejected extended limitation period, finding no willful suppression or deliberate misstatement by appellant. Penalties were set aside while demands were confined to normal limitation period with applicable interest. The tribunal dismissed appellant's revenue neutrality argument and distinguished factual differences from.........