Wages paid to labourers cannot form part of taxable value

P. Padmavathi supplied manpower to Crown Beers India and separately invoiced wages and service charges. 

The Department sought Service Tax on the entire amount, contending that the wage reimbursement did not qualify for exclusion under the pure-agent provisions. 

CESTAT held that the real question was whether the wages constituted consideration for the service. Since they were merely reimbursed and not retained by the appellant, only the service charges were taxable.