TMI Blog2011 (9) TMI 791X X X X Extracts X X X X X X X X Extracts X X X X ..... alogous to conversion of incomplete or unfinished into complete/finished article and hence it should amount to ‘manufacture’ - It is contended that, where the activity undertaken by the appellant amounted to manufacture, it would not be exigible to Service Tax under any head whatsoever - the appellant is directed to pre-deposit an amount of Rs. 3,00,000 - ST/2337/2010 - 810/2011 - Dated:- 13-9-20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g of worn-out dies is carried out on a special machine called thread grinding machine. The old thread is removed and the resulting blank is subjected to rethreading. Learned consultant submits that the entire activity, particularly whether it starts with the blank, amounts to manufacture in terms of Note 6 to Section XVI of the First Schedule to the Central Excise Tariff Act. The Section Note ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hould amount to manufacture . It is also pointed out that the appellant s case based on the Section Note was not considered by the learned Commissioner (Appeals). It is contended that, where the activity undertaken by the appellant amounted to manufacture, it would not be exigible to Service Tax under any head whatsoever. Learned consultant has also pointed out that the appellant is a SSI unit an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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