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    <title>2025 (9) TMI 997 - CESTAT ALLAHABAD</title>
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    <description>Embroidery work undertaken on a job-work basis was treated as manufacture rather than a taxable service, because the activity fell within the manufacturing character recognised under central excise law and was linked to Chapter 5810 of the Central Excise Tariff. The tribunal also found that the appellant and the proprietary concern were effectively the same entity, and the minor address variation did not alter that position. As the activity amounted to manufacture within section 2(f) of the Central Excise Act, 1944, the negative list entry for manufacturing activities applied, so the service tax demand and penalty under the Finance Act, 1994 were set aside.</description>
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      <description>Embroidery work undertaken on a job-work basis was treated as manufacture rather than a taxable service, because the activity fell within the manufacturing character recognised under central excise law and was linked to Chapter 5810 of the Central Excise Tariff. The tribunal also found that the appellant and the proprietary concern were effectively the same entity, and the minor address variation did not alter that position. As the activity amounted to manufacture within section 2(f) of the Central Excise Act, 1944, the negative list entry for manufacturing activities applied, so the service tax demand and penalty under the Finance Act, 1994 were set aside.</description>
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