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TMI Blog2017 (5) TMI 1203X X X X Extracts X X X X X X X X Extracts X X X X ..... idence of supply of manpower with details of number and nature of manpower, duration and other conditionalties for such supply. In absence of such evidence, the simple allegation that the appellant received some amount from the clients for job work and such amount should be taxed under “Manpower Recruitment and Supply Agency Service” is not sustainable - In absence of any supporting evidence, it i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Finance Act, 1994. The appellants claimed that they are doing job work of cutting footwear in the premises of M/s. Kabeer Textile Pvt. Ltd. , for which they raised bill periodically and received job charges. The dispute in the present appeal is relating to the liability of the appellant as Manpower Recruitment or Supply Agency . 3. I have heard both the sides and perused the appeal reco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er the instructions of the client. There is no written agreement in the arrangement. Both the Lower Authorities held against the appellant only on the ground that they have failed to substantiate their claim that they are not a Manpower Supply Agency . It was held that the appellants did not produce supporting documents to the effect that they are only doing job work or supporting the manufactur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dertaken by them. There is no evidence of supply of manpower with details of number and nature of manpower, duration and other conditionalties for such supply. In absence of such evidence, the simple allegation that the appellant received some amount from the clients for job work and such amount should be taxed under Manpower Recruitment and Supply Agency Service is not sustainable. In fact, the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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