TMI Blog2015 (7) TMI 27X X X X Extracts X X X X X X X X Extracts X X X X ..... cise duty by invoking longer period of limitation, without going into the legal issue as to whether the activity amount to manufacture or not, would not be appropriate inasmuch as the appellant was admittedly discharging the service tax liability on the activity undertaken by them with the due knowledge of the Revenue. As regards service tax, learned advocate fairly agrees that the same was collec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... addition, penalties also stand imposed upon the appellants. 2. After hearing both sides at length, we find that the appellant is undertaking the activity of fabricating various iron and steel items by cutting, drilling and making holes etc. The said activity is being done by them on job work basis for the principal manufacturers. By entertaining a view that the said activity does not amount to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ipal manufacturers, central excise duty was paid. Further, the appellants also stopped paying service tax from October 2010 onwards, though they were collecting the same from their customers. 3. In the above background, proceedings were initiated against them by way of issuance of show-cause notice raising demand for central excise duty for the period from April 2008 to February 2011, as also f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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