2017 (6) TMI 1232

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..... ndent : Sh. Amresh Jain, DR) JUDGEMENT PER B. RAVICHANDRAN : The present appeal is filed by the assessee-Appellants against the order-in-original no. 47/Commissioner/2013 dated 06.08.2013 passed by the Commissioner of Central Excise & Service Tax, New Delhi. 2. The assessee-Appellants in collaboration with Indian Oil Company Ltd. and Bharat Petroleum Corporation Limited had set up two joint ve .....

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..... that they are not a Manpower Recruitment or Supply Agency. They are a premium Government of India undertaking engaged in gas processing, distribution and marketing of natural gas. We have perused the terms of joint venture agreement. It is clear that, as a part of their obligation in setting up of the said joint venture, the assessee-Appellants are required to depute some qualified technical staff .....

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..... s Arvind Mills Ltd., 2014 (35) STR 496 (Guj.) and of the Hon‟ble Allahabad High Court in the case of CCE vs Computer Sciences Corporation India Pvt. Ltd., 2015 (317) STR 62 (All.). 4. Following the ratio of these decisions, we find that the assessee-Appellants cannot be put to tax liability under the category of 'Manpower Recruitment or Supply Agency's Service' for the activity now under di .....

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