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TMI Blog2015 (10) TMI 2287X X X X Extracts X X X X X X X X Extracts X X X X ..... Shri M R Sharma, AR For the Respondent : Shri Karan Sachdev, Adv. ORDER Per: Sulekha Beevi CS: The Revenue has filed this appeal challenging order of refund of cenvat credit of Rs. 21,20,532/-. 2. The respondent is a 100% EOU and engaged in the business of processing of chips, the activity which includes circuit designing, testing, validation of such chips, integration of software on chips a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... duct, designing chips, testing and validation of chips and customer support after sales. Conceptualization of semi conductor chip takes place based on feedback and requirement of the customer which is designed according to the customer's need. The respondent then conducts testing and validation of chips and also provide after sale support. According to him, this would come within the definitio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ding lottery, lotto, bingo; (iii) any customer care service provided on behalf of the client; or (iv) Procurement of goods or services, which are inputs for the client; or Explanation. - For the removal of doubts, it hereby declared that for the purposes of this sub-clause, "inputs" means all goods or services intended for use by the client;] [(v) Production or processing of goods for, or on b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... would come within the definition of Business Auxiliary Service under Section 65 (19) of the Finance Act.1994. Learned Counsel for the respondent also relied upon the decision of Tribunal in CC, Hyderabad vs Knoah Solutions Pvt.Ltd.-2010 (20) STR 691 (Tri.-Bang.) . The contention of the Revenue that the activity of processing of chips is a manufacturing process and that it would fall within the def ..... X X X X Extracts X X X X X X X X Extracts X X X X
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