Case of Alstom Transport India Ltd vs Comm of Commercial taxes, South Zone, HC Karnataka Judgement Dated 15th July 2025. It has been held that the secondment of expats does not constitute import of manpower supply service. The services rendered by employees to their employer are not liable to GST under Entry 1 of Schedule III of the CGST Act. The reimbursements are not consideration, and in the absence of invoice and with full ITC, no tax is payable under the CBIC Circular.