2009 (4) TMI 112

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..... ponents and machinery parts for a consideration. It cannot be said that they had undertaken the various activities on behalf of any other person. They had undertaken the activities themselves for a fee – demand is not sustainable.
Shri P. Karthikeyan, Member (Technical) (Final Order No. 375/2009 dt. 6.4.2009 certified on 9.4.2009 in Appeal No. ST/64/2007) Shri Joseph Prabhakar, Adv. for Appe .....

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..... nd penalties on the ground that during the material period service tax was attracted under BAS only in cases where the activity fell under the definition 'production of goods on behalf of the client'. This entry under BAS was substituted on 10.9.2004 with the entry 'production or processing of goods for, or on behalf of, the client.' The activity undertaken by the appellants could not be described .....

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..... It was only with effect from 16.6.2005 that such activities undertaken by a person for another was brought under BAS. As rightly argued by the learned counsel for the appellants, during the material period, which is prior to 16.6.2005, the appellants had engaged in certain activities which could be described as processing of goods for its customers. By virtue of the language of the entry, during t .....

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