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2023 (9) TMI 1438

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....he case are that the appellant is engaged in the manufacture and sale of excisable goods. The appellant entered into an agreement with M/s Tata Steel Limited for manufacturing job as Conversion Agent of Tata Steel Ltd. (TSL). The appellant operated as Conversion Agent of TSL in terms of the Conversion Agency Agreement. The appellant was also appointed as Consignment Agent of TSL for handling the said converted steel material on, inter alia, the terms and conditions set out in the Consignment Agency Agreement. With reference to the said Conversion Agreements, a third Agreement was entered into by and between TCIL and TSL, whereunder TCIL was appointed as Marketing Agent for marketing of TSL's products converted by it, on the terms and condit....

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....ry. 2.3 Thereafter, it is evident that the service in question rendered by TCIL during which its Consignment Agent carried out the handling job on which service tax is payable and was paid has nothing to do with any service rendered or to be rendered by TCIL under the Marketing Agency Agreement with TSL. 2.4 The Revenue is of the view that in terms of Marketing Agency Service, the appellant is providing the services under the category of "support of services of business and commerce" and liable to pay service tax thereon. 2.5 Therefore, the proceedings were initiated against the appellant for demanding the same. 2.6 The matter was adjudicated. The demand of service tax was confirmed. 2.7 Against the said order, the appellant is before ....