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2017 (1) TMI 170

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....nt ORDER Per Justice (Dr.) Satish Chandra The present appeals are filed against the order-in-original No. 30-32/2011(ST) dated 20.07.2011 passed by the Commissioner (Appeals), Central Excise, Jaipur. 2. The appellant during the period under consideration, was providing chilling facilities to Jaipur Zila Dugdh Utpadak Sahakari Sangh Limited. The department has brought the service under the Busi....

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....s auxiliary service under Section 65(19) of Finance Act, 1994. At this stage, we would like to reproduce Chapter Note 6 to Chapter 4: "6. In relation to products of this Chapter labelling or relabeling of containers or repacking from bulk packs to retail packs or the adoption of any other treatment to render the product marketable to the consumer, shall amount to manufacture". There is no dou....

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....iple should be applied for interpreting the scope of any other treatment and according to the said principle, only such other treatments which are similar to labelling or relabeling of containers or repacking from bulk packs to retail packs would only be covered under the scope of any other treatment and therefor chilling of milk would not be covered thereunder. We find that the other treatments m....