Erection and commissioning charges fell outside Consulting Engineer service for the pre-2003 period.

Erection, installation and commissioning charges were not covered within the scope of Consulting Engineer service under section 65(48) of the Finance Act, 1994 for the period prior to 2003. The activity involved site-based erection and commissioning of goods, which did not amount to consulting engineering, and the Board's circular also clarified that such charges were outside the taxable service. The charges were therefore not liable to Service Tax for the relevant period, and the Revenue's appeal failed.

---

---

Issues: Whether erection, installation and commissioning charges were leviable to Service Tax under the category of Consulting Engineer service for the period prior to 2003.

Analysis: The activity undertaken by the assessee consisted of erection and commissioning of goods at the customer's site, which was not covered within the scope of Consulting Engineer service as brought into existence under section 65(48) of the Finance Act, 1994. The Board's circular clarified that charges for erection, installation and commissioning were not covered under Consulting Engineer services prior to 2003.

Conclusion: The activity was not taxable as Consulting Engineer service for the relevant period, and the Revenue's appeal failed.

---