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of CESTAT allowed the appeal and set aside service tax demand against job-worker appellant engaged in pickling and oiling of HR coils for principal manufacturers during 2007-2015. Though activities constituted taxable Business Auxiliary Services under sub-clause (v), appellant was exempt under Notification 8/2005-Service Tax dated 01.03.2005 as amended, since raw materials were supplied by clients and processed goods returned to them for manufacturing excisable goods. Post-March 2012, Chapter Note 6 to Chapter 72 of CETA deemed pickling and oiling as manufacturing process attracting central excise duty, precluding service tax liability to avoid double taxation. Principal manufacturers had certified compliance with excise duty obligations. The tribunal concluded no service tax liability existed for the entire disputed period and allowed complete relief to appellant.
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