𝗖𝗘𝗦𝗧𝗔𝗧 𝗔𝗵𝗺𝗲𝗱𝗮𝗯𝗮𝗱 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗘𝗽𝗼𝘅𝘆 𝗖𝗼𝗮𝘁𝗶𝗻𝗴 𝗦𝗲𝗿𝘃𝗶𝗰𝗲𝘀 𝗮𝗻𝗱 𝗕𝘂𝘀𝗶𝗻𝗲𝘀𝘀 𝗔𝘂𝘅𝗶𝗹𝗶𝗮𝗿𝘆 𝗦𝗲𝗿𝘃𝗶𝗰𝗲𝘀 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗵𝗲𝗹𝗱: "Epoxy coating of pipelines qualifies as 'production of goods on behalf of the client' under 'Business Auxiliary Services' from 10-9-2004 onwards, but penalties are unwarranted due to lack of suppression or misstatement."

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗣𝗮𝗿𝘁𝗶𝗲𝘀: PSL Limited vs. C.C.E. & S.T. Rajkot 𝗜𝘀𝘀𝘂𝗲: Whether the appellant is liable to pay service tax, interest, and penalties under "Business Auxiliary Services"? 𝗔𝗰𝘁𝗶𝘃𝗶𝘁𝘆: The appellant, engaged in epoxy coating of pipelines, contested service tax liability under "Business Auxiliary Services" and sought penalty waiver.

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The Tribunal ruled that epoxy coating services became taxable post-10-9-2004 under "Business Auxiliary Services." No intent to evade tax was found, as the revenue was aware of the appellant's activities. While service tax and interest were upheld, penalties under Sections 76, 77, and 78 were set aside. Appeal partly allowed.

𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: PSL Limited vs. C.C.E. & S.T. Rajkot 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 27 February 2023 📜 This ruling clarifies that epoxy coating qualifies as taxable under "Business Auxiliary Services" post-10-9-2004 but highlights the absence of penalties due to lack of suppression or intent to evade tax.