TMI Blog2017 (10) TMI 348X X X X Extracts X X X X X X X X Extracts X X X X ..... Agency Service’. The issue stands covered by the judgment in the case of Aravind Mills Ltd. [2014 (4) TMI 132 - GUJARAT HIGH COURT], where it was held that company is not in the business of providing recruitment or supply of manpower. Actual cost incurred by the company in terms of salary, remuneration and perquisites is only reimbursed by the group companies. There is no element of profit or fin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Even in the appointment letter, the appellant had made it clear that they are required to work in the subsidiary companies also depending upon the job exigencies. That therefore the appellant is not liable to pay service tax under the category of Manpower Recruitment Supply Agency Service. She relied upon the judgment in the case of Commissioner of Service Tax Vs. Arvind Mills Ltd. - 2014 (35) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly held by the Tribunal. To recall, the respondent in order to reduce his cost of manufacturing, deputed some of its staff to its subsidiaries or group companies for stipulated work or limited period. All throughout the control and supervision remained with the respondent. As pointed out by the respondent, company is not in the business of providing recruitment or supply of manpower. Actual cost i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in providing any services directly or indirectly in any manner for recruitment or supply of manpower temporarily or otherwise to a client, in the present case, the respondent cannot be said to be a commercial concern engaged in providing such specified services to a client. It is true that the definition is wide and would include any such activity where it is carried out either directly or indir ..... X X X X Extracts X X X X X X X X Extracts X X X X
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