2015 (4) TMI 1003

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....Gaur, Advocate For the Respondent : Shri Govind Dixit, DR ORDER Per Mr. R.K. Singh : The Appeal has been filed against Order-in-Original No. COMMISSIONER/RPR/11/2009, dated 03.02.2009 in terms of which a service tax demand of Rs. 4,39,26,388/- was confirmed along with interest and penalties. 2. The facts of the case, briefly stated, are as under:- The appellants, manufacturers of....

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.... Services and accordingly confirmed the impugned demand along with interest and penalties. 3. The appellants have argued that (i) they were manufacturers of liquor and bottling, sealing, labelling, etc. were part of the overall process of manufacture upto the point of clearance and therefore they cannot be said to have provided Packaging Services . (ii) Their case is covered by the judgements i....

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....everages. It is also not the Revenue s case that the appellants were only doing packaging activities and the processes prior to packaging were done by someone else. In these circumstances, the appellants are clearly manufacturers of liquor. Indeed manufacturers of any product which involves packaging for clearance are never held to be providing packaging services because while every process of man....

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....ed the decision in the case of Vidhachal Distilleries Pvt. Ltd. Vs. State of M.P. [2006 (3) STR 723 (MP)]. As regards the contention of the Departmental Representative that in the present case the appellants were doing additional activities in addition to those covered in the case of Maa Sharada Wine Traders (supra), suffice to say that when the activities involved in the case of Maa Sharada Wine ....