The petitioners challenged show cause notices proposing levy of GST on secondment of employees from foreign group entities. The factual background indicated that salaries were paid by the Indian entities, and the seconded employees worked under their control. Subsequent clarifications issued by CBIC were also placed on record.

The Court held that once the issue of taxability of secondment stood clarified by the Board, continuation of proceedings was unwarranted. The impugned show cause notices were quashed, holding that the proposed levy was unsustainable in law.