TMI Blog2009 (4) TMI 112X X X X Extracts X X X X X X X X Extracts X X X X ..... us activities on behalf of any other person. They had undertaken the activities themselves for a fee – demand is not sustainable. - ST/64/2007 - 375/2009 - Dated:- 6-4-2009 - Shri P. Karthikeyan, Member (Technical) (Final Order No. 375/2009 dt. 6.4.2009 certified on 9.4.2009 in Appeal No. ST/64/2007) Shri Joseph Prabhakar, Adv. for Appellants. Shri R. P. Meena, SDR for Respondent. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the material period service tax was attracted under BAS only in cases where the activity fell under the definition 'production of goods on behalf of the client'. This entry under BAS was substituted on 10.9.2004 with the entry 'production or processing of goods for, or on behalf of, the client.' The activity undertaken by the appellants could not be described as on behalf of any other person. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 005 that such activities undertaken by a person for another was brought under BAS. As rightly argued by the learned counsel for the appellants, during the material period, which is prior to 16.6.2005, the appellants had engaged in certain activities which could be described as processing of goods for its customers. By virtue of the language of the entry, during the material period, unless a person ..... X X X X Extracts X X X X X X X X Extracts X X X X
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