TMI Blog2013 (12) TMI 104X X X X Extracts X X X X X X X X Extracts X X X X ..... anti-corrosion treatment. If the petitioner was providing the anti-corrosion treatment for its own material, there would be no question of a taxable service having been provided, since service to oneself is not a taxable service. The fundamental premise of the proceedings is that the petitioner was providing the anti-corrosion service to another by way of BAS. The goods processed by the petitione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... date after filing Returns. Petitioner claimed immunity to the liability to tax on the basis of Notification No. 8/2005-ST dated-01/03/2005.This claim was rejected by the adjudicating authority. 2. That the petitioner had provided the taxable BAS is not in dispute in this appeal. The only bone of contention is to the application of Notification No. 8/2005-ST. 3. Notification 8/2005-ST grants ex ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 4. To reject the claim of the petitioner, for the benefits of Notification No. 8/2005-ST, the Ld. Adjudicating authority proceeded on a fundamental misconception of the requirement of the Notification. Firstly, at para 14 of the order, the adjudicating authority erroneously extracted the conditions for application of the Notification. He recorded that the goods produced should "amount to manuf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eatment. If the petitioner was providing the anti-corrosion treatment for its own material, there would be no question of a taxable service having been provided, since service to oneself is not a taxable service. The fundamental premise of the proceedings is that the petitioner was providing the anti-corrosion service to another by way of BAS. The goods processed by the petitioner are received fro ..... X X X X Extracts X X X X X X X X Extracts X X X X
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