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    <title>2016 (3) TMI 201 - CESTAT MUMBAI</title>
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    <description>A lump sum job-work arrangement for cutting, drilling, punching, bending and notching carried out inside the recipient&#039;s factory as part of the manufacturing process was treated as execution of work, not supply of manpower. The activity occurred before the goods reached the RG-1 stage, and its cost formed part of the recipient&#039;s production cost on which central excise duty was paid. The description of the recipient as principal employer did not change the contractual substance. The service tax demand under Manpower Recruitment or Supply Agency Services was therefore unsustainable, and the assessee&#039;s relief was upheld.</description>
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      <description>A lump sum job-work arrangement for cutting, drilling, punching, bending and notching carried out inside the recipient&#039;s factory as part of the manufacturing process was treated as execution of work, not supply of manpower. The activity occurred before the goods reached the RG-1 stage, and its cost formed part of the recipient&#039;s production cost on which central excise duty was paid. The description of the recipient as principal employer did not change the contractual substance. The service tax demand under Manpower Recruitment or Supply Agency Services was therefore unsustainable, and the assessee&#039;s relief was upheld.</description>
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