Bottling of liquor treated as manufacture, so it falls outside taxable packaging activity and the Revenue's challenge failed.

Bottling of liquor was treated as manufacture, not as a mere packaging activity liable to service tax. The reasoning followed prior binding and consistently applied decisions that had already rejected the Revenue's contention on the same issue. On that basis, the relief granted by the lower appellate authority was sustained and the Revenue's challenge failed, leaving the impugned order undisturbed.

---

---

Issues: Whether bottling of liquor amounts to manufacture and is therefore outside the scope of taxable packaging activity.

Analysis: The issue had already been decided against the Revenue in prior binding and followed decisions holding that bottling of liquor amounts to manufacture. On that basis, the relief granted by the lower appellate authority was sustained.

Conclusion: Bottling of liquor was treated as manufacture and not as a taxable packaging activity; the Revenue's appeal was rejected.

Final Conclusion: The impugned order granting relief to the assessee was left undisturbed and the Revenue's challenge failed.

Ratio Decidendi: Where the activity of bottling liquor amounts to manufacture, it cannot be subjected to service tax as a mere packaging activity.

---