Secondment Taxation Limits

In a calibrated application of the Supreme Court’s secondment jurisprudence, the Tribunal has upheld service tax liability on cross-border manpower supply arrangements but decisively curtailed the reach of extended limitation and penalties.

The ruling underscores that while taxability may now be settled law, historical disputes rooted in interpretational ambiguity cannot be retrospectively recast as suppression.

The decision reinforces a crucial distinction between liability crystallisation and culpability attribution.