𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 – 𝗖𝗘𝗦𝗧𝗔𝗧 𝗔𝗵𝗺𝗲𝗱𝗮𝗯𝗮𝗱: 𝗦𝗲𝗿𝘃𝗶𝗰𝗲𝘀 𝗥𝗲𝗻𝗱𝗲𝗿𝗲𝗱 𝗯𝘆 𝗔𝗽𝗽𝗲𝗹𝗹𝗮𝗻𝘁 𝗖𝗮𝗻𝗻𝗼𝘁 𝗕𝗲 𝗖𝗹𝗮𝘀𝘀𝗶𝗳𝗶𝗲𝗱 𝗨𝗻𝗱𝗲𝗿 𝗠𝗮𝗻𝗽𝗼𝘄𝗲𝗿 𝗥𝗲𝗰𝗿𝘂𝗶𝘁𝗺𝗲𝗻𝘁 𝗮𝗻𝗱 𝗦𝘂𝗽𝗽𝗹𝘆 𝗔𝗴𝗲𝗻𝗰𝘆 𝗦𝗲𝗿𝘃𝗶𝗰𝗲𝘀 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗵𝗲𝗹𝗱: No manpower supply or recruitment by appellants; services rendered to sugar factory cannot be classified under manpower recruitment agency services.

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: Talala Taluka Sahakari Khand Udyog Mandali Limited 𝗜𝘀𝘀𝘂𝗲: Expenses charged to farmers for sugarcane harvesting and transportation do not qualify as "Manpower Recruitment or Supply Agency Services." 𝗔𝗰𝘁𝗶𝘃𝗶𝘁𝘆: The appellant's sugarcane harvesting and transportation expenses deducted from farmer payments were wrongly classified as "Manpower Recruitment and Supply Services."

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The Tribunal, relying on precedent, ruled that the appellant's activities lacked elements of manpower supply or recruitment. Contracts confirmed no provision of manpower to the sugar factory. The issue, deemed no longer res integra, reaffirmed that such activities do not qualify as "Manpower Recruitment and Supply Agency Services." Demand was unsustainable.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: Talala Taluka Sahakari Khand Udyog Mandali Limited vs. Commissioner of Service Tax, Ahmedabad – Service Tax 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 6 December 2022 📜 This ruling confirms that sugarcane harvesting and transportation activities without manpower supply are not taxable as manpower recruitment services.