GST on manpower supply includes lockdown wage reimbursements; no exemption from labour memo under CGST Act

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Full Text of the Document

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....The AAR held that the applicant's supply of manpower to a Govt. space research centre constitutes "manpower recruitment and supply services" and is a taxable supply under the CGST Act. Interim payments made by the recipient to outsourced workers during the COVID-19 lockdown, pursuant to contractual arrangements, form part of the consideration for such taxable services. The subsequent disbursement of the entire amount to workers does not alter the taxability or reduce the taxable value. The office memorandum treating contractual/outsourced staff as "on duty" during lockdown and directing continued payment of wages is a labour-protection measure and does not create any GST exemption. As no specific exemption applies, GST is payable on the full consideration, and the applicant must regularise the corresponding tax liability.....