2025 (7) TMI 1137

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....e demand of service tax of Rs.6,32,493/-under Section 73(1) of the Finance Act, 1994 along with interest under Section 75 and also imposed an equal penalty under Section 78 and a penalty of Rs.10,000/- under Section 77 of the Act. 2. Briefly stated facts of the present case are that the appellant is engaged in the manufacturing of wiring harness for automobiles and is registered with the Service Tax department under the categories of Transport of Goods by Road, Management Consultants, Consulting Engineers and Design Services. The appellant entered into agreement for transfer of personnel on secondment with M/s Delphi Automotive Systems Private Limited, Singapore (in short 'Delphi Singapore'). During the period of secondment, the ....

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....aken a number of grounds on merits as well as on limitation, but she confines her submissions on limitation alone. 4.1 The learned Counsel submits that the entire demand is barred by limitation. She further submits that vide the impugned order, demand of service tax has been confirmed for the period from 2004- 05 to 2007-08 as proposed in the SCN dated 23.10.2009. She further submits that the demand of service tax on the amount of salary reimbursed to Delphi Singapore under the head 'Manpower Recruitment and Supply Agency Service' pertains to the period 2006-07 and 2008-09. She further submits that the demand proposed vide the SCN dated 23.10.2009 for the period 2006-07 and 2007-08 is barred by limitation as during this period, t....

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....d, she places reliance on the following cases: a) Tesco Bengaluru Private Limited, Shri Karandeep Singh and Raja Pawha vs. Commissioner of Central Excise and Service Tax, Bengaluru - 2025 (2) TMI 1054 CESTAT Bangalore b) Daimler India Commercial Vehicles Pvt. Ltd. vs. Commissioner of CGST & C. Ex., Chennai Outer Commissionerate - 2025 (7) TMI 148 CESTAT Chennai c) M/s AGS Customer Services (India) Pvt. Ltd. vs. Commissioner of Service Tax-I, Pune - 2024 (6) TMI 1113 CESTAT Mumbai d) Commissioner of Central Tax, Bangalore North vs. M/s Fuji Furukawa Engineering and Construction Co. (India) Private Limited (FFECI) Level IV - 2024 (5) TMI 372 CESTAT Bangalore e) M/s Halcrow Consulting India Private ....