Order Date – 03 May 2023

Parties: Decorative Sleeves Pvt Ltd Vs C.C.E. & S.T.-Vadodara-ii

Facts – 

• The Appellant, Decorative Sleeves Pvt Ltd, undertook job work from three different parties. The job work involved printing on PVC films supplied by their clients. The appellants collected job charges.
• The department sought to tax the receipt of the job work charges under the head of Business Auxiliary Service. The same was confirmed holding that that the activity of printing does not amount to manufacture and therefore, the appellants are not entitled to benefit of Notification No. 14/2004-ST.

Issue – 

• Whether Job work charges are taxable under the head of Business Auxiliary Service?

Order – 

• The Tribunal observed that Notification No. 14/2004-S. T., dated 10-9-2004 exempts production of goods on behalf of client and any service incidental or ancillary to production of goods. 
• In the instant case, it is not in dispute that the appellants are printing on PVC material supplied by their clients. Printing may or may not amount to manufacture, but it cannot be denied that the activity of printing is an activity of production. In these circumstances benefit of Notification No. 14/2004-ST, as amended cannot be denied to the appellant.
• The notification not only covers the activity of production of goods but also any activity incidental or ancillary to production of goods. In these circumstances the activity of printing on PVC done by the appellant can be considered to be activity of production of goods.
• The appeal is allowed.