CAV ORDER

In the captioned petition, petitioner is assailing the orders dated 16.10.2024 vide Annexures-A to A5 passed by respondent No.4 and a further declaration is sought that the taxable value of the supply, if any, made by the overseas entities/expats to the petitioner is 'Nil' in terms of Section 15(4) of the Central Goods and Service Tax Act, 2017 (for short 'the CGST Act, 2017') read with Rule 28 of the CGST Rules, 2017. A further declaration is sought for payment of salary made to the expats by the petitioner does not attract IGST on the ground that it does not amount to manpower and recruitment supply of services from the overseas group entities to the petitioner/company.

2. The facts leading to the case are as under:

The petitioner is engaged in the business of designing, manufacturing, supplying, installing, and commissioning goods pertaining to railway and metro infrastructure projects. In addition, the petitioner provides design and engineering services, including software upgradation and modification in metro projects. During the disputed period from July 2017 to March 2023, the petitioner avers that employees of its overseas group companies were seconded to work in I