Employees seconded by group co. can’t be considered as Manpower Recruitment Services, thus no ST to be paid

EXCISE/ST/VAT : Where assessee were engaged in providing software development and IT enabled services and Commissioner by impugned order had confirmed demand along with interest and penalties on ground that assessee had evaded payment of service tax on 'Manpower Recruitment and Supply of Manpower Agency Service', it was held that persons seconded to assessee by its group company were working in capacity of employees and payment of salaries etc.

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