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2018 (5) TMI 830 - AT - Service TaxManpower Recruitment or supply Agency service - extended period of limitation - Held that: - the issue of extended period was already discussed by the lower authorities and we agree with it. Regarding the quantum, it is evident that the assessee-Appellant is claiming that the services of “Manpower Recruitment or supply Agency” by any person after 01.05.2006 were brought under the clutches of Section 65(68) of the Finance Act, 2006 and prior to it only commercial concern were taxable. An identical issue has come up for consideration before the Tribunal in the case of Charanjeet Singh Khanuja vs CST, Indore, [2015 (6) TMI 585 - CESTAT NEW DELHI], where it was held that notwithstanding the fact that w.e.f. 1-5-2006 the term, ‘commercial concern’ in Section 65(105)(zzb) was replaced by ‘any person’, we are of the view that even during the period prior to 1-5-2006, the Business Auxiliary Service, even if provided by an individual to a client, was taxable. Appeal dismissed - decided against assessee-Appellant.
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