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of The CESTAT held that the appellant is not liable to pay service tax under 'Mining Services' for 2008-2017, as the activities of coal extraction and crushing amount to manufacture, attracting excise duty, not service tax. The appellant's payments of excise duty and VAT confirm this classification. Regarding sponsorship services, the Tribunal remanded the issue to the adjudicating authority for detailed examination of documentary evidence to distinguish between donations and sponsorships. The appellant was found compliant with Rule 6(3)(i) of the Cenvat Credit Rules, 2004, as they maintained proper records and did not claim credit on exempted solar power services, negating the demand on this ground. Consequently, no penalty was imposed due to the absence of a sustainable demand. The appeal was disposed of accordingly.
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