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    <title>2019 (10) TMI 534 - CESTAT AHMEDABAD</title>
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    <description>Job-work fabrication, machining, welding, assembling and galvanising performed on goods received under the prescribed challan procedure were treated as Business Auxiliary Service rather than Works Contract Service. The Works Contract Service definition had to be applied independently and could not be determined by importing meanings from another statute; the activities were also exempt where the specified job-work procedure applied and the principal manufacturer paid duty on final products. The extended limitation period was unavailable because the dispute concerned statutory interpretation and the job-work arrangement, with no wilful suppression to evade tax. Revenue neutrality further supported the conclusion that the demand was time-barred. The impugned order was set aside with consequential reliefs.</description>
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