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CESTAT analyzed the taxability of conversion charges under a job work agreement. The tribunal determined that the interest and depreciation payments did not constitute a rental service. The key finding was that the agreement was exclusively for manufacturing goods, not renting immovable property. The tribunal held that the conversion charges were not consideration for a service, but part of a manufacturing activity. Consequently, the service tax demand was rejected, and the appeals were allowed, affirming that the transaction did not meet the criteria for service tax under the Finance Act, 1994.
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