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2018 (7) TMI 179 - AT - Service TaxService or manufacture? - The customers supplied the drawing for preparation of moulds, which are required to be used for the manufacture of forging - whether taxable under the category of “design services” or not? - Held that:- It is observed that the design and drawing supplied by the customers have been utilized by way of design and preparation of the moulds within the factory. It is evident that the moulds are, in fact, prepared within the factory and the product came into existence in the factory and is liable to payment of excise duty if the same is cleared out of the factory. The activity undertaken by the appellant is nothing but the manufacture of moulds and hence levy of service tax on such amount under the category of design services under Section 65(105)(zzzzd) of the Finance Act, 1994, is not justified. Appeal allowed - decided in favor of appellant.
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