Coal Sizing Process Classified as "Manufacture" Under Central Excise Act, Not Subject to Business Auxiliary Service Tax.

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....Valuation - Business Auxiliary Service (BAS) - Sizing of coal is an incidental and ancillary process to make coal marketable and thus complete “manufacture” of coal and to make it into “excisable goods” as per Section 2(d) of the Central Excise Act. The process of sizing of coal is also therefore outside Section 65(19) of the Act since it is a process in the manufacture of the final product, sized coal. - AT....