2023 (6) TMI 899

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.... Mr. Joydip Chattopadhyay , Authorized Representative for the Respondent ORDER PER ASHOK JINDAL : The facts of the case are that the appellant has received conversion charges from M/s. Organon (India) Ltd. for undertaking manufacture of oral contraceptive medicines under the brand names- 'Novelon', Femilon', 'Elogen', etc. The said excisable goods were exempted from payment of central exci....

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....hat the fact that the appellant is engaged in manufacturing of pharmaceuticals products is not disputed by the revenue. As these fact is not disputed by the Revenue, the case of the appellant is squarely covered by the CBEC Circular vide Letter Dy. No. 2305/Commr(ST)/2011, dated 15-7-2011, wherein Paragraph 4 has recorded as under:- "4. In your said letter at Para 5 it is mentioned that embroide....

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....y this Tribunal in the case of Samrajya and Company Vs. CCE 2019 (24) G. S. T. L. 221 (Tri.-Chennai), which is held as under:- 5.4 In the circumstances, the activities carried out by the appellant will indeed amount to 'manufacture' for the purpose of Section 2(f) of the Central Excise Act,1994 and in consequence, the same will not be a Business Auxiliary Service under Section 65 (19) of the Fina....