https://www.taxtmi.com/caselaws?id=751956 Crushing lumps into powder may amount to manufacture where Chapter Note 2 of Chapter 25 deems the process as manufacture and the product emerges with a different name, character and use. On that basis, the activity falls outside Business Auxiliary Service because the statutory definition excludes activities amounting to manufacture of excisable goods. The analysis also notes that, where the issue was subject to divergent views and genuinely debatable, the extended period of limitation cannot be invoked. The resulting service tax demand was therefore treated as unsustainable and barred by limitation, with consequential relief following. en-us Fri, 26 Apr 2024 00:00:00 +0530 Tue, 30 Apr 2024 13:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751956 Crushing lumps into powder may amount to manufacture where Chapter Note 2 of Chapter 25 deems the process as manufacture and the product emerges with a different name, character and use. On that basis, the activity falls outside Business Auxiliary Service because the statutory definition excludes activities amounting to manufacture of excisable goods. The analysis also notes that, where the issue was subject to divergent views and genuinely debatable, the extended period of limitation cannot be invoked. The resulting service tax demand was therefore treated as unsustainable and barred by limitation, with consequential relief following. Case-Laws Service Tax Fri, 26 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751956