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2023 (5) TMI 606

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..... ture, 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 pro .....

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..... ase of M/s. Caprihans (India) Ltd (supra), the process under taking by the appellant amounts to manufacture and therefore, the activities under taken by them is not covered in definition of Business Auxiliary Services. He pointed out that the activity of printing is exempt from the levy of Service Tax under Business Auxiliary Services in term of Notification 14/2004-ST. He pointed out that Notification 14/2004- ST dated 10.09.2004, has modified by Notification No. 19/2005-ST dated 07.06.2005 and Notification No. 19/2006-ST dated 25.04.2006. The activity under taking by the appellant is exempt. He pointed out that they are engaged in printing activity. He further pointed out that extended period has been invoked in the instant case. He point .....

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..... of India; (v) a co-operative society established by or under any law; (vi) a corporation established by or under any law; or (vii) a body corporate established by or under any law, unless such factory, company, partnership firm, society, cooperative society, corporation or body corporate, as the case may be, provides any business auxiliary service in respect of any activity specified in (a) to (d) above in relation to agriculture, printing , textile processing or education. [Notification No. 14/2004-S. T., dated 10-9-2004. 4.1 The said Notification 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 a .....

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