https://www.taxtmi.com/caselaws?id=212335 The exclusion from Business Auxiliary Service applies to manufacture as such, not merely to manufacture of excisable goods. Manufacture was understood in its settled sense as bringing into existence a new substance through a process that transforms raw material. On that basis, the activity of preparing the product under the agreement was treated as manufacturing activity, and the fact that the final product was not excisable did not remove it from the manufacturing exclusion. That was sufficient to establish a prima facie case for complete waiver of pre-deposit, and stay of recovery was granted during the appeal. en-us Mon, 25 Jul 2011 00:00:00 +0530 Thu, 23 Feb 2012 11:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212335 The exclusion from Business Auxiliary Service applies to manufacture as such, not merely to manufacture of excisable goods. Manufacture was understood in its settled sense as bringing into existence a new substance through a process that transforms raw material. On that basis, the activity of preparing the product under the agreement was treated as manufacturing activity, and the fact that the final product was not excisable did not remove it from the manufacturing exclusion. That was sufficient to establish a prima facie case for complete waiver of pre-deposit, and stay of recovery was granted during the appeal. Case-Laws Service Tax Mon, 25 Jul 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212335