TMI Blog2017 (11) TMI 350X X X X Extracts X X X X X X X X Extracts X X X X ..... t and Supply Agency service as defined under sub clause (k) of Section 65(105) of the Finance Act, 1994 and liable for Service Tax? - Held that: - from shareholding pattern it is seen that some companies share holding is less than 50%, therefore it cannot be said that these are subsidiaries of the appellant - Similarly in other subsidiary companies it has to be ascertained, whether in of case diff ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 82,05,655/- under the category of Manpower Recruitment and Supply Agency was confirmed, also demanded interest under Section 75 and imposed penalty under Section 78. 2. The issue involved in the present case is that whether the employees of the appellant deputed to the their other group companies against which they received consideration towards remuneration of those employees during 2006-07 to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of all the group companies to whom the appellant have deputed their manpower. The appellant filed letter dated 30-7-2017 and submitted share holding pattern of all the group companies, which was taken on record. 3. On the other hand, Shri. B. Kumar lyer, Ld. Superintendent(A.R.) appearing on behalf of the Revenue reiterates the findings of the impugned order. 4. We have carefully considered ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n some companies share holding is less than 50%, therefore it cannot be said that these are subsidiaries of the appellant. Similarly in other subsidiary companies it has to be ascertained, whether in of case different limited company, whether there is relationship of service provider and service recipient. Since the adjudicating authority has not gone into details of constitution of the each compa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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