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2017 (4) TMI 895 - AT - Service TaxTaxability - manpower recruitment and supply services - payments received by lessor on behalf of the workers used by the lessee of a factory for carrying out their operations in the category of ‘manpower recruitment and supply services’ - Held that: - we do not find any role for the respondent as an intermediary. The employees, originally recruited by the lessor, were placed at the disposal of the lessee as part of that agreement which allowed the latter to operate the distillery. It would appear that the terms of remuneration are also not the subject of the agreement between the lessor and the lessee and we do not find any clause that specifies period of employment of these workers with the lessee - nature of the transaction between the respondent and the lessee and its failure to conform to the description of the taxable service takes the service out of ambit of taxable service - appeal dismissed - decided against Revenue.
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