TMI Blog2018 (4) TMI 774X X X X Extracts X X X X X X X X Extracts X X X X ..... that: - the respondent was established with the sole objective of providing the hospitality business of itself and through its associated companies. Since the actual expenses incurred by the respondent towards deployment of the managerial personal were reimbursed by the hotels on actual basis, without any markup, it cannot be said that such expenses should be considered a service fee, taxable unde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Singh, DR. PER S.K. MOHANTY: Brief facts of the case are that the respondent is registered with the Service Tax Department for providing various taxable services , defined under the Finance Act, 1994 . As per the Operating Services Agreement entered into between the respondent and its subsidiaries/joint ventures/associates, the respondent stationed various Managerial / Supervisory a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sement of salaries and perks of the managers deployed to associate/subsidiary hotels do not attract taxability under such category of service . Feeling aggrieved with the impugned order , Revenue has filed this appeal before the Tribunal . 2. The ld. DR appearing for the Revenue reiterated the grounds of appeal urged in the appeal memorandum . 3. On the other hand, Id. Advocate appeari ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in ITC standards and run its operation in a smooth and efficient manner. Since the respondent and those hotels are independent cost centers, the salary and other cost were recovered on actual basis, without any markup. It is a n undisputed fact on record that the respondent is not engaged in the business of providing/ recruiting/ supply of man power. Rather, the respondent was established with the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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