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    <title>2025 (6) TMI 1592 - CESTAT  AHMEDABAD</title>
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    <description>Fabrication of wind mill parts was treated as manufacture of goods rather than provision of a taxable service because the fabricated items brought into existence excisable goods covered by the applicable exemption notification. As the goods manufactured at the relevant time fell within the exempt category, the activity retained its character as manufacture and could not be reclassified as a service transaction for service tax purposes. Service tax on the fabrication activity was therefore held unsustainable.</description>
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      <description>Fabrication of wind mill parts was treated as manufacture of goods rather than provision of a taxable service because the fabricated items brought into existence excisable goods covered by the applicable exemption notification. As the goods manufactured at the relevant time fell within the exempt category, the activity retained its character as manufacture and could not be reclassified as a service transaction for service tax purposes. Service tax on the fabrication activity was therefore held unsustainable.</description>
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