Business Auxiliary Service does not cover incidental supply of heated oil to adjacent units; service tax not attracted.

The supply of heated thermic fluid or heated hydraulic oil to neighbouring units, against hourly heating charges, did not constitute Business Auxiliary Service because the activity was confined to heating oil for use in the assessee's own factory and transferring only excess heated oil through pipelines to adjacent units. The arrangement did not involve procurement of goods or services for a client through a third person, nor did it amount to a client-oriented taxable service. Accordingly, the activity was held not liable to service tax.

---

---

Issues: Whether the supply of heated thermic fluid or heated hydraulic oil to neighbouring units, for which heating charges were received on an hourly basis, constituted "Business Auxiliary Service" and attracted service tax.

Analysis: The activity consisted of heating hydraulic oil for use in the assessee's own factory and supplying only the excess heated oil through pipelines to adjacent units. The arrangement did not involve procurement of goods or services for a client through a third person, nor did it amount to rendering a service of the nature contemplated under "Business Auxiliary Service". The supply was treated as an incidental transfer of excess heated oil after use in the assessee's own premises, rather than a taxable client-oriented service.

Conclusion: The activity did not amount to "Business Auxiliary Service" and was not liable to service tax.

---