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    <title>2020 (2) TMI 1450 - CESTAT BANGALORE</title>
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    <description>Processing, cleaning, cooking, freezing, packing and labelling of raw marine products supplied by customers was treated as manufacture because the activity produced a commercially distinct and marketable product. The processes were covered by Chapter Note 3 to Chapter 16, which deems labelling, relabelling, repacking and similar treatment that renders goods marketable to be manufacture under Section 2(f) of the Central Excise Act, 1944. As a result, the activity did not fall within Business Auxiliary Service under Section 65(19) of the Finance Act, 1994, and was not exigible to service tax on that basis. Reliance on Sterling Foods was rejected as arising in a different statutory context.</description>
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