2024 (1) TMI 331

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....en & Ms Taniya Roy, both Advocate for the Appellant Mr. K. Chowdhury, Authorized Representative for the Respondent ORDER The Appellant is manufacturer of razor and razor blades. The have availed the services of Manpower Services during the period December 2005 to February 2008. Based on the Bills raised by the service provider wherein the details of Service Tax is clearly shown, the Appel....

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....de the factory premises are also mentioned. As a matter of fact, the services 'sales promotion', 'market research' and 'activity relating to absence' etc., are very much applicable for all the services provided by the manpower service provider. Therefore, he submits that the Adjudicating Authority is in error in confirming the demand. 3. The Learned Counsel also submits that the Show Cause Noti....

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.... 4. The Learned AR reiterates the findings of the Adjudicating Authority and justifies the confirmed demand. 5. Heard both sides and perused the Appeal Papers and the documentary evidence placed before us. 6. The definition of input service during the period under dispute is extracted as follows:- 2(l) "input service" means any service,- (i) Used by a provider of taxable s....

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.... transportation upto the place of removal; 7. We find that the Adjudicating Authority has taken a very narrow view holding that the Manpower Service should be relatable only to the 'manufacturing activity' and not to any other activities outside the factory premises. We find this view to be grossly erroneous. Had he taken care to go through the definition of input service in a harmonious way, h....