TaxTMI 
TaxTMI 
2015 (1) TMI 1139
X X X X Extracts X X X X
X X X X Extracts X X X X
....A.R., for the Appellant/Department. Shri Sudhir Malhotra, Advocate with A.S. Hasija, Consultant, for the Respondent/Assessee. ORDER Show cause notice dated 13-9-2007 alleged that during the period February 2005 to March 2006, the respondent provided three taxable services - (a) Coal Handling and Loading; (b) Manpower Recruitment or Sup....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ea manufactured by NFL was merely being collected in bags from bagging plants and these bags were stacked on the conveyor. The conveyor system then carried the bags to railway wagons or trucks. Assessee's employees were merely stacking the bags on the railway wagons or trucks as the case may be, and therefore, activity falls outside the purview of cargo handling service. 3. In respect of m....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ecting or sterilizing. Employees of the assessee only clean the conveyor belts and the conveyor system for facilitating efficient conveyance of packed bags of fertilizers from the bagging plant to the railway wagon/trucks and thus the activity does not fall within the ambit of cleaning service. 5. The Additional Commissioner, Central Excise, Ludhiana by the adjudication order dated 18-3-20....
X X X X Extracts X X X X
X X X X Extracts X X X X
....andling service. 6. On analysis of the transactional documents including contract and the work orders, ld. appellate Commissioner also concluded that cleaning of the conveyor systems for transport of the fertilizer bags does not fall within the ambit of cleaning activity. Appellate Commissioner further held that assessee's activity fall outside the ambit of manpower recruitment or supply a....