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    <title>2019 (6) TMI 326 - CESTAT ALLAHABAD</title>
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    <description>Chilling, pasteurization, homogenization and standardization of raw milk into toned milk were treated as manufacture because the process produced a marketable product that was distinct from the raw material by name, use and characteristics. Chapter Note 6 to Chapter 4 operated as a deeming provision where treatment renders the product marketable to consumers, and the activity therefore fell within manufacture rather than business auxiliary service. As manufacture is excluded from the scope of business auxiliary service, the service tax demand and penalties could not be sustained. The limitation plea was not examined because the matter was decided on merits.</description>
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