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TMI Blog2015 (12) TMI 671X X X X Extracts X X X X X X X X Extracts X X X X ..... ertakes the activity of grading the diamonds, it also does some activity of inscription because of which the essential character of the diamonds does not change and it still remains the diamond. - none of these activities could amount to the manufacture of diamonds so as to invite the provisions of Central Excise Act. A contention was raised by Shri Jain that the activity of certification may invite some duty as it amounts to service. However, we clarify that we are not deciding that issue, since, we are not asked the question as to whether the certification of diamonds amounts to service or not in this application. - activity undertaken by the applicant does not amount to manufacture and, hence, will not attract the provisions of Cent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r weight in carats. The second activity undertaken is that of inscription. The applicant has given a detailed account of the activity of inscription in paragraph 5 which is as under:- The applicant submits that the word inscription of diamonds service means applying the Forevermark ; a unique identification/inscription number on the diamonds that is not even visible to the naked eye to ensure the product is securely traceable. It is pertinent to note that a customer is able to confirm this is a genuine product with the help of this unique number. It is relevant to note that, the activity of inscription does not affect the internal quality of a diamond in any way. The activity of inscription is proposed to be carried out through equi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to both FM UK and IIDGR UK. IIDGR India shall provide the service of grading and inscription of the 'Forevermark' to FM UK and the facility of generic grading and inscription to IIDGR UK. It is proposed that for the provision of the said services, IIDGR India shall raise monthly invoices on FM UK and IIDGR UK. 7. It is clear to us that none of these activities could amount to the manufacture of diamonds so as to invite the provisions of Central Excise Act. A contention was raised by Shri Jain that the activity of certification may invite some duty as it amounts to service. However, we clarify that we are not deciding that issue, since, we are not asked the question as to whether the certification of diamonds amounts to servic ..... X X X X Extracts X X X X X X X X Extracts X X X X
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