Whether de-shelling and re-shelling of old and worn out sugar mill rollers is liable for service tax under Maintenance or Repair service?

The Appellants are engaged in the manufacture of sugar mills machinery, heavy gears and steel casting, paper mill machinery, Diesel Engines etc. They also do de-shelling and re-shelling of old and worn out sugar mill rollers which are sent to them by various sugar mills when such rollers become old and worn out and requires reconditioning before further use. The moot point in this appeal is whether such de-shelling and re-shelling is liable to service tax under the head “Maintenance or Repair” during the period July 03 to Nov 05. IN THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRI...