2001 (4) TMI 137

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.... The appellants being technical consultants, are an engineering concern and entered into a contract with M/s. South India Viscos Ltd. for designing and fabrication of steel storage tanks. The steel sheets and other raw materials were procured and transported to the client's factory site in Palani Taluk (Tamil Nadu) and the tanks of 22 feet height or so, were fabricated at the site of factory of M/....

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....n to site and first a tank is fabricated at site which is then lifted and placed in position and permanently attached to the earth/building, then a water tank comes into existence as goods capable of being brought and sold in the market and is liable to Central Excise duty. But where such tank comes into existence by fixing piece by piece while attached to the earth, it would be regarded as part o....