The department challenged the order passed by CESTAT wherein, the tribunal, inter alia, held that the activity of digital offset and offset printing amounts to manufacture and the same is classifiable under heading chapter 4911 of the Central Excise Tariff. Therefore, no service tax would be payable on such activity. The department/ revenue contented that the activity undertaken by the assessee in relation to “digital offset printing” was a service leviable to service tax under the category of “photography services” both prior and post introduction of negative list regime came to be negated.
The Supreme Court rejected the arguments of the revenue and held that there is no substantial question of law requiring consideration. Accordingly, upheld the order of the Tribunal and dismissed the department SLP.
Commr. of CGST vs. M/s SRK Kreative Pvt. Ltd. -SCA No. 912 of 2021 (SC)
