2023 (5) TMI 606 - AT - Service Tax

Exemption from service tax - Job work - printing of PVC film/ sheets - Manufacturing activity vs Processing of goods -Business Auxiliary Service or printing activity - printing of PVC film/ sheets amounts to manufacture under Section 2 (f) of Central Excise Act, 1944 - applicability of N/N. 14/2004-ST - Extended period of limitation - HELD THAT:- The N/N. 14/2004-ST exempts production of goods on behalf of client and any service incidental or ancillary to production of goods. In the instant case, it is not in dispute that the appellants are printing on PVC material supplied by their clients. Printing may or may not amount to manufacture, but it cannot be denied the activity of printing is an activity of production. In these circumstances benefit of Notification No. 14/2004-ST, as amended cannot be denied to the appellant.

It is notice that the impugned order holds that the activity of printing does not amount to manufacture and therefore, the appellants are not entitled to benefit of Notification No. 14/2004-ST. It is to be seen that the activity of production of goods is different from the activity of manufacture. The notification not only covers the activity of production of goods but also any activity incidental or ancillary to production of goods. In this circumstances the activity of printing on PVC done by the appellant can be considered to be activity of production of goods.

The appeal is allowed.