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    <title>2026 (6) TMI 952 - CESTAT KOLKATA</title>
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    <description>Activity undertaken under a principal-to-principal processing arrangement was treated as manufacture, not a taxable service, because the raw material, machinery and technical know-how were supplied by GCPL while the appellant used its labour and premises to produce goods cleared on central excise duty. Applying its earlier decisions on identical arrangements, CESTAT held that once the activity satisfied manufacture under section 2(f) of the Central Excise Act, 1944, it could not be subjected again to service tax under the Finance Act, 1994, including under the negative list regime. The service tax demand was therefore unsustainable and was set aside.</description>
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