TMI Blog2024 (2) TMI 1159X X X X Extracts X X X X X X X X Extracts X X X X ..... y, Senior Advocate Assisted by Shri Abhijit Biswas, Advocate For the Appellant Shri J. Chattopadhyay, Authorized Representative For the Respondent ORDER The appellant is in appeal against the impugned order wherein the demand of service tax under the category of "support of services of business and commerce" is confirmed. 2. The facts of the case are that the appellant is engaged in the manufa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ible for safe custody of TSL's materials right from the time the materials for conversion were received by it till they were delivered after conversion to the designated or nominated or identified party or parties of TSL, for and on its behalf. 2.2 As per the said Conversion Agency Agreement TCIL, upon receiving the Hot Rolled Coil from TSL, converted the said raw material into finished products ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ices is clearly stated along with cess payable thereon. It is this service tax amount and cess thereon paid, of which CENVAT Credit is availed by TCIL, as and by way of input service, in its factory. 2.3 Thereafter, it is evident that the service in question rendered by TCIL during which its Consignment Agent carried out the handling job on which service tax is payable and was paid has nothing to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt and therefore, the same treatment should be given to the present Show Cause Notice and the demands. 4. Heard the parties and perused the records. 5. We find that in the appellant's own case for an earlier period (supra), this Tribunal observed as under: - "5. We find that during the course of hearing of the Stay Petition by this Tribunal, a report was sought from the Commissioner, Jamshedpu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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