Service Tax not leviable on Packing services incident to Manufacturing of Goods

M/s. Narain Packaging Vs. Commissioner of Service Tax (CESTAT Delhi) Admittedly, the packaging is subsequent to manufacture of paper by M/s. J K Paper Ltd. The appellants claim that they have contributed to the incidental activity of manufacture. We note that the appellants are engaged in packing activity in the premises of clients. The cut size paper manufactured by M/s. J K Paper were given to the appellant direct and using their packing machine the appellant undertakes the wrapping, packing in box, strapping and returns the completed goods back to client. These operations are inside the man...