Commissioner of GST & Central Excise Respondent Chennai South Commissionerate MHU Complex, No. 692, Anna Salai Nandanam, Chennai 600 035. APPEARANCE: Shri Raghavan Ramabhadran, Advocate for the Appellant Ms. T. Usha Devi, JC (AR) for the Respondent CORAM Hon'ble Ms. Sulekha Beevi C.S., Member (Judicial) Hon'ble Shri P. Anjani Kumar, Member (Technical) Final Order No. 40735 / 2021 Date of Hearing : 13.01.2021 Date of Pronouncement: 24.02.2021 Per Ms. Sulekha Beevi C.S. The above matter has come up for hearing as per the remand order of the Hon'ble High Court in CMA No. 655/2020 dated 4.8.2020. This Tribunal had disposed the appeal vide Final Order No. 40401/2019 dated 27.2.2019. The Revenue filed an appeal against such order before the Hon'ble High Court and as per the judgment in the abovementioned CMA, the Hon'ble High Court has remanded the matter to rehear issue No. 4 on merits as well as on the ground of 2 Service Tax Appeal No.178 of 2012 limitation. The relevant portion of the judgment of the Hon'ble High Court is noticed as under: "7. Mere reference of the citations in the order and then holding that the extended limitation could not be invoked to the Revenue is a serious prejudice caused to the interest of the Revenue, in the absence of discussing the Order dt.04.08.2020 in C.M.A.No.655 of 2020 relevant facts, and giving reasons, for arriving at a particular conclusion. We are restraining ourselves from expressing anything further on the tenor of the order passed by the learned Members of the Tribunal in the present case. 8. We hope and expect that the learned Members, and even other Members, who deal with the appeals from now onwards, in such Revenue matters, should understand the letter and spirit of these observations of the High Court. 9. We accordingly set aside the said order of the learned Tribunal on the said issue no.4, regarding taxability of manpower services and application of extended limitation in the present case and restore the appeal back to the learned Tribunal, with a request to hear the appeal de novo on the said issue and decide the same as expeditiously as possible. We are not in a position to answer the questions raised by the Revenue in the present appeal at this stage, for the aforesaid reasons. 10. The appeal is accordingly disposed of, without any order as to costs." 2. Issue No. 4 is in regard to the demand of service tax on Manpower Recruitment or Supply Agency Service (hereinafter referred to as MRSA services) for the period 16.6.2005 to 2007 08. 3. The appellant is engaged in providing information technology related solutions including maintenance of software etc. They are paying service tax under Information Technology Software Services after such services have become taxable in 2008. The department was of the view that for the period prior to 2008, as per the agreements entered by the appellant with various clients, the appellants have rendered MRSA services to these clients. This allegation has been defended by the appellant stating that the services are nothing but Information Technology Software Services for which they have been 3 Service Tax Appeal No.178 of 2012 paying service tax after 2008 and that these activities will not fall under the definition of MRSA. 4. On behalf of the appellant, ld. Counsel Shri Raghavan Ramabhadran appeared and argued the matter. He submitted that the appellant is a global IT services and consultancy company providing IT solutions for business in Banking, Financial and Insurance Sectors. The appellant offers IT solutions by way of application development and maintenance, business intelligence and data warehousing, application integration, testing, conversion / migration / reengineering etc. The Hon'ble High Court has remanded the matter to reconsider Issue No. 4 where the demand raised under manpower recruitment and supply agency service for the peri