2015 (2) TMI 240

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....ngle Dose Bio-availability Study  of amoxicillin 875 mg capsules in healthy male and female volunteers/Fasting State. The fees agreed and to be paid for the said service is 95,380 CDN (Canadian) dollars. ii. For this purpose, Amoxicillin manufactured and packaged by the appellants hereinafter also called APL would be supplied to ALOG. Four types of services were rendered by ALOG to APL (i) General services as per the protocol supplied by APL (ii) Clinical services (iii) Bio-analytical services through Pracs Institute (iv) Storage services of the inventory of drug received from APL and other free samples. iii. The appellants where registered under the head Management Consultants  with the Hyderabad-II Commissionerate of Centr....

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....stating that as per Section 65 (106) of the Finance Act, 1994, Technical Testing & Analysis  excluded any testing or analysis service provided in relation to human beings or animals and as the services provided by ALOG to the appellants were in relation to testing on human beings, it should stand excluded from the purview of service tax. viii. Appellants had also received SCN O.R. No.17/2005 ST (Adjn.) dated 19.12.2005 from the Hyderabad-II Commissionerate stating that the services provided by ALOG to the appellants fell under the service category Scientific or Technical Consultancy Services . The appellants replied to this SCN through their reply dated 23.2.2006. Apart from other submissions, the appellant also submitted that two s....