2024 (8) TMI 1649

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....Shri K. Anpazhakan, Member (Technical) For the Appellant : Shri Deepro Sen, Advocate Ms. Taniya Roy, Advocate. For the Respondent : Shri S. S. Chattopadhyay, Authorized Representative. ORDER PER SHRI ASHOK JINDAL The appellant is in appeal against the impugned order wherein demand of service tax has been confirmed against them for the period of 10.09.2004 to 28.02.2005 by issuance o....

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....under 'business auxiliary service'. 3. The appellant replied to the queries, but the impugned Show Cause Notice was issued by invoking the extended period of limitation, to demand service tax under the category of business of auxiliary service, alleging that activity of heat treatment amounts to production of goods on behalf of the client, which did not amount to manufacture, and thereby being ....

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.... period of limitation is not invokable in the facts and circumstances of the case. 5. On the other hand, the Ld. Authorized Representative appearing for the Revenue submitted that the said activity is an activity of production of goods on behalf of their client and the decision in the case of M/s. Excel Industries v. Commissioner of GST AND Central Excise, Tiruchirapalli [2024(5) TMI 1341-CESTA....

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....n manufacture of excisable goods by the principal manufacturer, namely, M/s. Tata Motors Ltd. Therefore, we observe that the facts of this case are identical to the facts of the case of Hi-Tech Induction Pvt. Ltd. (supra), wherein this Tribunal has held as under: - "4. We find that the respondents are receiving job work of Heat Treatment of automobile p-arts mainly crankshafts from their ....