2017 (12) TMI 165

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..... - for the respondent ORDER Per: B. Ravichandran The appeal is against the order dated 20.7.2010 of Commissioner (Appeals), Indore. The appellants are engaged in providing various services to M/s Kriti Industries Ltd. and M/s Laxmi Solvex Dewas, in connection with manufacturing activity of these two clients. The activities mainly relate to loading, unloading of receipts of soyabean seed ....

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....y Service, the appellants are liable to pay service tax. The original authority proceeded to confirm their tax liability holding that these activities carried out by them or incidental or auxiliary to the production and manufacturer goods by the clients. Whereas the impugned order confirmed the liability holding that the appellants were helping in procurement of goods for the clients and as such c....

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...., the original order and the impugned order, we note that the Revenue could not make up their mind as to which category of BAS will apply to the activities of the appellants. Admittedly, the appellants carried out a whole range of activities loading, unloading of raw materials and up to loading de oiled cake for despatch. In between they have attended to various take of type of work in the clients....