https://www.taxtmi.com/caselaws?id=797344 Output-based conversion and packaging of Third Schedule biscuits constituted manufacture, not manpower supply, because consideration depended on packed quantity and the process rendered goods marketable. The activity was consequently covered by the service-tax exclusion for processes amounting to manufacture. Reverse-charge demands for security, GTA and legal services did not arise where security services were provided by a tax-charging body corporate, freight entries included non-GTA expenses or settled audit liabilities, and legal-service invoices concerned consultants rather than advocates. Extended limitation and penalties were unavailable because the dispute was interpretational, based on audited statutory records, and lacked fraud, wilful misstatement or suppression intended to evade tax. en-us Tue, 18 Aug 2026 00:00:00 +0530 Fri, 21 Aug 2026 08:28:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797344 Output-based conversion and packaging of Third Schedule biscuits constituted manufacture, not manpower supply, because consideration depended on packed quantity and the process rendered goods marketable. The activity was consequently covered by the service-tax exclusion for processes amounting to manufacture. Reverse-charge demands for security, GTA and legal services did not arise where security services were provided by a tax-charging body corporate, freight entries included non-GTA expenses or settled audit liabilities, and legal-service invoices concerned consultants rather than advocates. Extended limitation and penalties were unavailable because the dispute was interpretational, based on audited statutory records, and lacked fraud, wilful misstatement or suppression intended to evade tax. Case-Laws Service Tax Tue, 18 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797344