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TMI Blog2019 (2) TMI 952X X X X Extracts X X X X X X X X Extracts X X X X ..... etter of Universities stating that they had done printing work in the period of dispute and some work orders containing details of nature of work order done and document for making payments also stand scrutinized by him. From perusal of Profit & Loss Account, ITR, etc. it cannot be concluded rather the Bills, Work Orders, etc. produced by them clearly show that such work was awarded by Universities, Professional Exam Council, etc. who are Public Educational Institutions and not doing any commercial activities for Business or Commerce. Consequently, the appellant can also not be alleged for supporting any business activity of their clients. As regards work done for private firm M/s MCM, I find that such printing work of Universities, Exa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ellant were engaged in the activity of ICR Form scanning and Processing. Designing and processing of admit cards/verification cards/roll sheets etc. for various Universities etc. these activities amounted to processing of transactions in relation to procedure of admissions, conduct of examinations and result tabulation etc. on behalf of customers. They were also engaged in other transaction processing viz. data processing and ICR Scanning for their customers. The confidential job or contract work etc. mentioned by their clients was nothing but various activities, as mentioned above, undertaken by them for their clients. They are also engaged in similar work on sub-contract for other firm viz. M/s Management Control Systems, Lucknow M/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er, Central Excise, Lucknow, wherein, he inter-alia observed that on perusal of documents (Bills, work order, certificate, etc.), it has been found that the appellant has produced number of documentary evidence clearly showing that the work undertaken by the appellant was printing of aforesaid stationery for use by their clients Universities/Institutions/Exam Councils which is not covered by the above definition of the alleged category of taxable service i.e. BSS . In absence of any contrary documentary evidence to support the allegation of the department, he agreed with the contention of the party and therefore, held that the work undertaken by the appellant during the relevant period is printing of stationery for Universities/Instituti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs containing details of nature of work order done and document for making payments also stand scrutinized by him. Accordingly, he has observed as under:- I find from the Order-in-Original itself that documents viz. Bills, Balance Sheets, ITR, Form-16A, CA s Certificate, etc. were also submitted before the Department/Adjudicating Authority with defence reply to notice but the Adjudicating Authority did not pay heed to their submission and abruptly concluded that the appellant were providing Business Support Service to their clients. I find that from perusal of Profit Loss Account, ITR, etc. it cannot be concluded rather the Bills, Work Orders, etc. produced by them clearly show that such work was awarded by Universities, Professional ..... X X X X Extracts X X X X X X X X Extracts X X X X
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