https://www.taxtmi.com/caselaws?id=763262 Packing bulk finished goods into retail packs was treated as manufacture under the Central Excise Act and the relevant tariff chapter notes, so the activity fell outside service tax liability. The demand and penalties could not be sustained because the department relied mainly on statements that were later retracted and not tested in the manner required by section 9D, while the other documentary material did not alter the legal character of the activity. The dispute was one of legal classification rather than suppression, so the extended period of limitation was not available. The service tax demand, interest, and penalties were set aside. en-us Fri, 13 Dec 2024 00:00:00 +0530 Tue, 17 Dec 2024 08:42:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763262 Packing bulk finished goods into retail packs was treated as manufacture under the Central Excise Act and the relevant tariff chapter notes, so the activity fell outside service tax liability. The demand and penalties could not be sustained because the department relied mainly on statements that were later retracted and not tested in the manner required by section 9D, while the other documentary material did not alter the legal character of the activity. The dispute was one of legal classification rather than suppression, so the extended period of limitation was not available. The service tax demand, interest, and penalties were set aside. Case-Laws Service Tax Fri, 13 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763262