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TMI Blog2017 (1) TMI 170X X X X Extracts X X X X X X X X Extracts X X X X ..... hat There is no doubt that chilling of milk is a treatment which renders the milk marketable. Consequently by virtue of the chapter note, chilling of milk amounts to manufacture and it is settled law that process amounting to manufacture is not liable to service tax - demand not sustained - appeal allowed - decided in favor of appellant. - S.T. Appeal Nos. 1530 - 1531 of 2011 - Final Order Nos. 5 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r the appellant and Sh. Sanjay Jain, ld. AR for the Revenue. 4. After hearing both the sides, it appears that as the issue has come up before the Tribunal in appellant s own case reported as 2016-TIOL-2273-CESTAT-DEL where it was observed that:- 5. It is evident from the above quoted para that in the case of Sharma Ice Factory the Tribunal came to a finding that chilling of milk does not a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch are located at considerable distances. That chilling of milk is a treatment is too obvious to warrant any explaining / discussion. Consequently by virtue of the said chapter note, chilling of milk amounts to manufacture and it is settled law that process amounting to manufacture is not liable to service tax. In the light of the above analysis, we agree with the decision/ conclusion in CESTAT ju ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... containers and repacking from bulk packs to retail packs do not form part of a family to which any other treatment has to belong as per the requirement of the principle of noscitur sociis. Further, it does not cover just any other treatment but only such other treatment which is adopted to render the product marketable to the consumers and so the definition is not too wide and unwieldy to be requi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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