Credit eligibility on tower and cabins used in providing Passive Telecom Infrastructure Service.

Case:-GTL INFRASTRUCTURE LTD VERSUS COMMISSIONER OF SERVICE TAX, MUMBAI

Citation:-2014-TIOL-1768-CESTAT-MUM

Brief facts:-The appellant is in appeal against the impugned order wherein demand has been confirmed on account of denial of CENVAT Credit availed by the appellant along with interest and penalties under Section 77 & 78 of the Finance Act, 1994.
The brief facts of the case are that the appellant is engaged in various types of activities such as creating telecom infrastructure and providing 'Output Service' to his client/customers. As the only dispute which arises before the tribunal is whether the stated service provided by the appellant is covered under Business Auxiliary Service. Therefore, the same is considered in the appeal in question. For that purpose the appellant is doing the following activity:
They were planning for providing 'Passive Telecom Infrastructure' by its installation at various sites to be used by the Cellular Telecom Operators, which could be shared by two or more Operators, while the appellant was to operate and maintain the 'Passive Telecom Infrastructure' and provide committed uptime in excess of 99% to the Operators.

In this proposed business plan of the Appellant, multiple Cellular Telecom Operators then could share the said 'Passive Telecom Infrastructure' by putting their antennas and other equipment, to send and receive electronic signals for their Cellular Telephony Services.
The proposed revenue model for appellant comprised of –
Provisioning of charges for providing the 'Passive Telecom Infrastructure' to the Cellular Operators for enabling them to provide their 'Cellular Telephony Services', and
Operations and Maintenance Fees for operating and maintaining the said Passive Telecom Infrastructure.

The appellants sought clarification from the respondents vide letter dt. 22.8.2005 to clarify whether the said activity of Passive Telecom Infrastructure comprising of tower/masts/pole, shelter, battery banks, DG Sets etc. attracts service tax under the category of Business Auxiliary Service. It was informed to the appellant vide letter dt. 20.9.2005 that they are liable to pay service tax under the category of Business Auxiliary Service' on the above said activities. In June 2009 Audit was conducted in the premises of the appellant and certain information were sought from the appellant. Department objected to availment of Cenvat Credit on parts of Towers, BTS Cabins etc., thereafter three show cause notices were issued to the appellant which are as under:-

S.No.	SCN No. & date	Amount of demand	Period of demand	Issue involved
1	V/ST/Dn.Bel/IAD/GTL/Infra/2009/775 dated 22.10.2011	Rs.69,19,02,601/-	2006-07 to 2010- 11	Wrong availment of Cenvat credit on Towers/parts etc.
2	V/Dn.V/Bel/AD/GTL/Infra/2009 dated 12.10.2012	RS.67,25,973/-	2011-12	Wrong availment of Cenvat credit on Towers/parts etc.
3	V/St.Dn-V/Gr-VI/CERA/GTL/Infra/1471 dated 12.03.2013	Rs.48,58,069/-	August 08 to August'09	Wrong availment of Cenvat credit on Capital Goods used in Jammu & Kashmir
	Total	Rs.70,34,86,643/-

The show cause notices were replied by the appellants to the adjudicating authority. After considering the contentions of the appellant and relying on the decision of Bharti Airtel Ltd. Vs. Commissioner of Central Excise, Pune reported in 2013 (29) S.T.R. 401 (Tri.-Mumbai) 2012-TIOL-209-CESTAT-MUM, Commissioner of C.Ex., Mumbai-IV Vs. Hutchison Max Telecom P. Ltd. 2008 (224) E.L.T. 191 (Bom.) 2008-TIOL-1509-CESTAT-DEL and Vandana Global Ltd. V. Commissioner of C.Ex., Raipur 2010 (253) E.L.T. 440 (Tri.-LB) 2010-TIOL-624-CESTAT-DEL-LB adjudicating authority held that the appellants are not entitled to avail Cenvat Credit on the above said items. Therefore, Cenvat Credit was denied and the same was demanded along with interest and various penalties under the Finance Act, were imposed. Aggrieved from the said order, appellant is before Tribunal.

Appellant Contentions:-The Ld. Counsel for the appellant submits that the appellants have been providing 'Passive Telecom Infrastructure' and the said activity was held by the Revenue as liable to pay service tax under the category of 'Business Auxiliary Service'. Therefore, it is submitted that the appellant being a service provider is entitled to take Cenvat Credit as per the Rule 2(k)(ii) of the Cenvat Credit Rules 2004. It is further submitted by the Ld. Counsel that initially appellant took the Cenvat Credit as capital goods but if these are not capital goods then it was pleaded that same may be treated as inputs for providing output service. He also submits that in the impugned order, the adjudicating authority has gone on the premise that as appellant is a manufacturer of goods which get attached to the earth and become immovable goods. Therefore, the same are not excisable goods, hence credit is not allowed. In fact the appellant is providing service and service provider is entitled to avail Cenvat Credit as per Rule 2(k)(ii) of the Cenvat Credit Rules, 2004. It is also submitted that the adjudicating authority has highly relied on the decision of Bharti Airtel Ltd.(supra). The said case has no relevance to the facts of this case. As in the said case, the assessee was a Cellular Phone Service Provider/Telecom Operator and to provide the said service they installed certain towers which become immoveable as per Circular No. 137/315/2007-CX-4 dt. 26.2.2008. In the circular it has been clarified that Cenvat Credit is not available on tower and parts thereof to Cellular Phone Service Provider as held in the case of Bharti Airtel Ltd.(supra). In the case of Bharti Airtel Ltd. this Tribunal proceeded with the case on the facts of appellant being a Cellular Phone Service Provider. Therefore, the said decision has no relevance to the facts of the present case. He further submits that in the case of Hutchison Max Telecom P. Ltd. (supra), the Hon'ble High Court was dealing with the issue whether the activity undertaken by the respondent amounts to manufacture as per Section 2(f) of the Central Excise Act, 1944, and thereafter arrived at as in the said case. The activity undertaken by the respondents in that case did not pass the test of marketability and consequently 'goods' and therefore Cenvat was denied on inputs used in manufacture. But in this case at hand the facts are altogether different from the said case. Moreover, the case of Vandana Global Ltd. (supra) has also no relevance to the facts of this case as in that case the activity was done by manufacturer not by a service provider and the case dealt with Cenvat Credit of inputs used in the manufacture of structural items. Therefore, he prayed that the impugned order be set aside and appeal be allowed.

Respondent Contentions:-On the other hand, learned AR opposed the contention of the Ld. Counsel and submits that the Cenvat Credit Rules provided for Cenvat Credit availment across goods and services. Therefore, credit on input goods can be used against payment of excise duty on input goods and against payment of service tax on output service. Similarly, Cenvat Credit on input service can be used for the provisions of output service or against the payment of excise duty of output goods. Therefore, the Cenvat Credit Rules provide that in order to avail credit nexus/relationship must be established between input use and output provide whether they are output goods or output service.
Learned AR further submitted that in this case credit on input cannot be used on output goods namely telecom tower as the tower is treated as immovable property and not goods. The Cenvat Credit on input goods would be available if it is used in relation to service of erection and commissioning of telecom tower and service charges on such activity are charged under the category as erection and commissioning of telecom tower. In all other situations, Cenvat Credit on input goods cannot be availed as the principle of relationship and nexus with the output service is not established in terms of Section 37(2) of the Central Excise Act, 1994. It is submitted that in this case the output service on which input goods is sought to be availed is running of telecom tower. The input goods namely cement and steel have no relationship with output service namely running of telecom tower. Therefore, the credit on these goods cannot be availed in relation to the service tax activity of renting of telecom tower. Therefore the appellants are not entitled for Cenvat Credit.

Reasoning of Judgment:-Heard both sides and considered their detailed submissions.
To conclude the issue in hand, first we have to examine the provisions of Cenvat Credit Rules for availment of Cenvat Credit, as the appellant has contended that they are claiming that CenvatCredit be allowed on the goods in question as inputs. Therefore, we are not discussing the issue whether the appellants are entitled to Cenvat Credit as capital goods. In these circumstances, we may examine the definition of inputs which has been described under Rule 2(k) of the Cenvat Credit Rules, 2004.
(k) "input means-
(i) all goods, except light diesel oil, high speed diesel oil and motor spirit, commonly known as petrol, used in or in relation to the manufacture of final products whether directly or indirectly and whether contained in the final product or not and includes lubricating oils, greases, cutting oils, coolants, accessories of the final products cleared along with the final product, goods used as paint, or as packing material, or as fuel, or for generation of electricity or steam used in or in relation to manufacture of final products or for any other purpose, within the factory of production;
(ii) all goods, except light diesel oil, high speed diesel oil, motor spirit, commonly known as petrol and motor vehicles, used for providing any output service;
Explanation 1. —The light diesel oil, high speed diesel oil or motor spirit, commonly known as petrol, shall not be treated as an input for any purpose whatsoever.
Explanation 2.-Input include goods used in the manufacture of capital goods which are further used in the factory of the manufacturer; [but shall not include cement, angles, channels, Centrally Twisted the deform bar (CTD) or Thermo Mechanically Treated bar (TMT) and other items used for construction of factory shed, building or laying of foundation or making of structures for support of capital goods];
On going through the above said provision of Rule 2(k)(i) ibid we find it deals with manufacturing activity. Admittedly, the appellants are providing output service, therefore, Rule 2k(ii) ibid is relevant to the facts of the case in hand, wherein it has been said that "all goods, except light diesel oil, high speed diesel oil, motor spirit, commonly known as petrol and motor vehicles, used for providing any output service", The adjudicating authority has heavily relied on Explanation-2 to the said Rules as same has been discussed by the Tribunal in the case of Bharati Airtel Ltd. (supra). In fact, the explanation also clarified that inputs includes goods used in manufacture of capital goods which are further used in the factory of the manufacturer. But in the case in hand, the appellant is a service provider. Therefore, the said explanations has no relevance to the facts of this case. As per Rule 2 (k) (ii) of the Cenvat Credit Rules, 2004 all goods are entitled for Cenvat Credit which are used for providing any output service. In this case nowhere it is disputed by any of the parties that the tower/BTS cabins were not used by the appellant for providing service namely 'Business Auxiliary Service'. Therefore, the Cenvat Credit cannot be denied. These facts have not been appreciated by the adjudicating authority and the adjudicating authority heavily relied on the definition of inputs as per Rule 2(k) (i) and Explanation-II to the said Rule. We also find that before discharging their service tax liability, the appellant narrated activity undertaken by them to the Revenue and Revenue directed the appellant to pay service tax under the category of 'Business Auxiliary Service' on the said activity. In that case the Cenvat Credit taken on the inputs for providing that service is entitled for Cenvat Credit as per Rule 2(k) (ii) of the Cenvat Credit Rules, 2004. Further, we find that the adjudicating authority has heavily relied upon the decision of Bharti Airtel Ltd.(supra); in the said case the facts are totally different to the facts of the case in hand. In fact in that case appellant was engaged in providing cellular telephone service and as per Board Circular No. 137/315/2007 CX-4 dt. 26.2.2008, it is clarified that no Cenvat Credit on towers and BTS cabin is permissible for Cellular Phone Service Provider. In the instant case, the towers and the cabins are used by the appellant as Passive Telecom Infrastructure for providing output service namely 'Business Auxiliary Service' as declared by the appellant to the department in 2005 and agreed to by the department in their reply dt. 20.9.2005.
We further find that in this case the intention of the appellant and their client (Operators) is to confer the Operators a right to install active infra network equipment including GSM Antenna and BTS equipment, and to extend and receive, highly specialized technical service, which includes the provision of creation and maintenance of highly controlled artificial temperatures and humidity levels at all times and continuous power supply at the prescribed voltage so as to operate the equipment of the operators, and thus be conducive to the functioning of the Operator's signal transmission for their ultimate consumers. In these circumstances, we hold that appellant are entitled for input service credit on towers and cabin, which have been used by the appellant for providing output service under the category of 'Business Auxiliary Service' in the facts of the case.
We further find that the 1 st show cause notice has been issued to the appellant for the period 2006-07 to 2010-11 on 22.10.2011 by invoking the extended period of limitation. As nothing has been suppressed by the appellant and they sought clarification about the liability before providing said service. Therefore, demand of extended period of limitation is also not sustainable. Further, we find that in the 3 rd show cause notice Cenvat Credit has been denied to the appellant on the capital goods used in the State of Jammu & Kashmir. It is the contention of the appellant that they made an entry in their books for availment of Cenvat Credit on the goods used in Jammu & Kashmir, but on pointing out they immediately reversed the said credit without utilizing the same. Therefore, they are not entitled to pay interest as per the decision of the Hon'ble High Court of Karnataka in the case of Commissioner of C.Ex., & S.T., LTU, Bangalore Vs. Bill Forge Pvt. Ltd.reported in 2012 (279) ELT 209 (Kar.) 2011-TIOL-799-HC-KAR-CX.
We have examined the decision of Bill Forge Pvt. Ltd.(supra) wherein the Rule 14 of the Cenvat Credit Rules 2004 was examined which states that where the Cenvat credit has been taken or utilized wrongly or has been erroneously refunded the same along with interest shall be recovered from the manufacturer or the provider of output service.
After examining the said provisions of Rule 14 of the Cenvat Credit Rules, 2004 the Hon'ble High Court also considered the decision of Union of India Vs. Ind-Swift Laboratories Ltd. reported in 2011 (265) ELT 3 (SC) = 2011-TIOL-21-SC-CXand arrived at a decision as under:
The Apex Court in the case of UNION OF INDIA vs. M/s. IND-SWIFT LABORATORIES LTD., - 2011-TIOL-21-SC-CX in Civil Appeal No.1976/2011[2011 (265) E.L.T. 3 (S.C.)] interpreting Rule 14 of CENVAT Credit Rules, 2004 held as under:-
A bare reading of the said Rule would indicate that the manufacturer or the provider of the output service becomes liable to pay interest alongwith the duty where CENVAT credit has been taken or utilized wrongly or has been erroneously refunded and that in the case of the aforesaid nature the provision of Section 11AB would apply for effecting such recovery.
We have very carefully read the impugned Judgment and order of the High Court. The High Court proceeded by reading it down to mean that where CENVAT credit has been taken and utilized wrongly, interest should be payable from the date the CENVAT credit has been utilized wrongly for according to the High Court interest cannot be claimed simply for the reason that the CENVAT credit has been wrongly taken as such availment by itself does not create any liability of payment of excise duty. Therefore, High Court on a conjoint reading of Section I lAB of the Act and Rules 3 & 4 of the Credit Rules proceeded to hold that interest cannot be claimed from the date of wrong availment of CENVAT credit and that the interest would be payable from the date CENVAT credit is wrongfully utilized. In our considered opinion, the High Court misread and misinterpreted the aforesaid Rule 14 and wrongly read it down without properly appreciating the scope and limitation thereof. A statutory provision is generally read down in order to save the said provision from being declared unconstitutional or illegal. Rule 14 specifically provides that where CENVAT credit has been taken or utilized wrongly or has been erroneously refunded, the same along with interest would be recovered from the manufacturer or the provider of the output service. The issue is as to whether the aforesaid word 'OR' appearing in Rule 14, twice, could be read as "AND" by way of reading it down as has been done by the High Court. If the aforesaid provision is read as a whole we find no reason to read the word "OR" in between the expressions 'taken' or 'utilized wrongly' or has been erroneously refunded as the word "AND". On the happening of any of the three aforesaid circumstances such credit becomes recoverable along with interest.
We do not feel that any other harmonious consideration is required to be given to the aforesaid expression/ provision which is clear and unambiguous as it exists all by itself. So far as Section 11AB is concerned, the same becomes relevant and applicable for the purpose of making recovery of the amount due and payable. Therefore, the High Court erroneously held that interest cannot be claimed from the date of wrong availment of CENVAT credit and that it should only be payable from the date when CENVAT credit is wrongly utilized. Besides, the rule of reading down is in itself a rule of harmonious construction in a different name. It is generally utilized to straighten the crudities or ignoring out the creases to make a statute workable. This Court has repeatedly laid down that in the garb of reading down a provision it is not open to read words and expressions not found in the provision/ statute and thus venture into a kind of judicial legislation. It is also held by this Court that the Rule of reading down is to be used for the limited purpose of making a particular provision workable and to bring it in harmony with other provisions of the statute.
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2. Therefore, the attempt of the High Court to read down the provision by way substituting the word "OR" by an "AND" so as to give relief to the assessee is found to be erroneous. In that regard the submission of the counsel for the appellant is well founded that once the said credit is taken the beneficiary is at liberty to utilize the same, immediately thereafter, subject to the Credit Rules."
As is clear from the aforesaid judgments, the Apex Court in the case of UNION OF INDIA Vs. M/s. IND-SWIFT LABORATORIES LTD., was essentially concerned with the interpretation placed by the Punjab and Haryana High Court where it had held that Rule 14 of the Cenvat Credit Rules, 2004 had to be read down to mean that where Cenvat credit has been taken or utilized wrongly interest should be payable on the Cenvat credit from the date the said credit had been utilized wrongly and that interest cannot be claimed simply for the reason that Cenvat credit has been wrongly taken as such availment by itself does not create any liability of payment of excise duty. Further they held that the word 'OR' appearing in Rule 14 twice could be read as 'AND' by way of reading it down. Disagreeing with the said reasoning, the Apex Court held that Rule 14 specifically provides that where Cenvat has been taken or utilized wrongly or has been erroneously refunded, the same along with interest would be recovered from the manufacturer or the provider of the output service. If the aforesaid provision is read as a whole we find no reason to read the word 'OR' in between the expression 'taken' or 'utilized wrongly' or 'has been erroneously refunded' as the word 'AND'. On the happening of any of the three aforesaid circumstances such credit becomes recoverable along with interest. Therefore the High Court erroneously held that interest cannot be claimed from the date or wrong availment of Cenvat credit, that they should be payable from the date when the Cenvat credit is wrongly utilized. Therefore the attempt on the High Court to read down the provision by way of substituting the word 'OR' by an 'AND' so as to give relief to the assessee is found to be erroneous.
In view of the aforesaid authoritative pronouncement of the Apex Court, the word 'OR' found in Rule14 cannot be read as 'AND'. Further, once the credit is taken or utilized wrongly or has been erroneously refunded, such credit becomes recoverable along with interest. In fact, in the case before the Apex Court, the assessee received inputs and capital goods from various manufacturers/ dealers and availed Cenvat credit on the duty paid on such materials. The investigations conducted indicated that the assessee had taken Cenvat credit on fake invoices. When proceedings were initiated, the assessee filed applications for settlement of proceedings and the entire matter was placed before the Settlement Commission. The Settlement Commission held that a sum of Rs.5,71,47,148-00 is the duty payable and simple interest at 10% on Cenvat credit wrongly availed from the date the duty became payable as per Section 11 AB of the Act till the date of payment. The Revenue calculated the said interest up to the date of the appropriation of the deposited amount and not up to the date of payment. Therefore it was contended that interest has to be calculated from the date of actual utilization and not from the date of availment. Therefore, an application was filed for clarification by the assessee. The said application was rejected upholding the earlier order, i.e., interest is payable from the date of duty becoming payable as per Section 11-AB. Therefore the Apex Court interfered with the judgment of the Punjab and Haryana High Court and rightly rejected by the Settlement Commission as outside the scope and they found fault with the interpretation placed on Rule 14.
Rule 14 of the CENVATCredit Rules, 2004 reads as under: Rule 14. Recovery of CENVAT credit wrongly taken or erroneously refunded. Where the CENVATcredit has been taken or utilized wrongly or has been erroneously refunded, the some along with interest shall be recovered from the manufacture or the provider of the output service and the provisions of sections 11A and 11ABof the Excise Act or sections 73 and 75 of the Finance Act, shall apply mutatis mutandis for effecting such recoveries.
A reading of the aforesaid provisions makes it very clear that the said provision is attracted where the Cenvat Credit has been taken or utilized wrongly or has been erroneously refunded. In view of the aforesaid judgment of the Apex Court, the question of reading the word'and' in place of 'or' would not arise. It is also to be noticed that in the aforesaid Rule, the word 'avail' is not used. The words used are 'taken' or 'utilized wrongly'. Further the said provision makes it clear that the interest shall be recovered in terms of Section 11A and 11B of the Act.
From the aforesaid discussion what emerges is that the credit of excise duty in the register maintained for the said purpose is only a book entry. It might be utilised later for payment of excise duty on the excisable product. It is entitled to use the credit at any time thereafter when making payment of excise duty on the excisable product. It matures when the excisable product is receivedfrom the factory and the stage for payment of excise duty is reached. Actually, the credit is taken, at the time of the removal of the excisable product. It is in the nature of a set off or an adjustment. The assessee uses the credit to make payment of excise duty on excisable product. Instead of paying excise duty, the cenvat credit is utilized, thereby it is adjusted or set off against the duty payable and a debit entry is made in the register. Therefore, this is a procedure whereby the manufacturers can utilize the credit to make payment of duty to discharge his liability. Before utilization of such credit, the entry has been reversed, it amounts to not taking credit. Reversal of cenvat credit amounts to non-taking of credit on the inputs.
Interest is compensatory in character, and is imposed on an assessee, who has withheld payment of any tax, as and when it is due and payable. The levy of interest is on the actual amountwhich is withheld and the extent of delay in paying tax on the due date. If there is no liability to pay tax, there is no liability to pay interest. Section 11 AB of the Act is attracted only on delayed payment of duty i.e., where only duty of exercise has not been levied or paid or has been short levied or short paid or erroneously refunded, the person liable to pay duty, shall in addition to the duty is payable from the date of book entry, showing entitlement of Cenvat credit. Interest cannot be claimed from the date of wrong availment of CENVAT creditand that the interest would be payable from the date CENVAT credit is taken or utilized wrongly.
In the instant case the facts are not in dispute. The assessee had availed wrongly the Cenvat credit on capital goods. Before the credit was taken or utilized, the mistake was brought to its notice. The assessee accepted the mistake and immediately reversed the entry. Thus the assessee did not take the benefit of the wrong entry in the account books. As he had taken credit in a sum of Rs.11,691-00, a sum of Rs.154-00 was the interest payable from the date the duty was payable, which they promptly paid. The claim of the Revenue was, though the assessee has not taken or utilized this Cenvat credit, because they admitted the mistake, the assessee is liable to pay interest from the date the entry was made in the register showing the availment of credit. According to the Revenue, once tax is paid on input or input service or service rendered and a corresponding entry is made in the account books of the assessee, it amounts to taking the benefit of Cenvat credit. Therefore interest is payable from the date, though, in fact by such entry the Revenue is not put to any loss at all. When once the wrong entry was pointed out, being convinced, the assessee has promptly reversed the entry. In other words, he did not take the advantage of wrong entry. He did not take the Cenvat credit or utilized the Cenvat Credit. It is in those circumstances the Tribunal was justified in holding that when the assessee has not taken the benefit of the Cenvat credit, there is no liability to pay interest. Before it can be taken, it had been reversed. In other words, once the entry was reversed, it is as if that the Cenvat credit was not available. Therefore, the said judgment of the Apex Court has no application to the facts of this case. It is only when the assessee had taken the credit, in other words by taking such credit, if he had not paid the duty which is legally due to the Government, the Government would have sustained loss to that extent. Then the liability to pay interest from the date the amount became due arises under Section 11 AB in order to compensate the Government which was deprived of the duty on the date it became due. Without the liability to pay duty, the liability to pay interest would not arise. The liability to pay interest would arise only when the duty is not paid on the due date. If duty is not payable, the liability to pay interest would not arise.
The case in hand although the appellant has taken the Cenvat Credit, the same has been reversed on pointing out therefore the facts of this case are similar to the case of Bill Forge Pvt. Ltd. (supra) and distinguishable from the facts of the case of Ind-Swift Laboratories Ltd. (supra), as in the case of Ind-Swift Laboratories Ltd. (supra), the Cenvat Credit was taken by the assessee on the strength of fake invoice and credit was not reversed by them but it was recovered by way of demanding duty. Therefore, the said facts are not applicable to the facts in hand. In these terms, we hold that the appellants are not liable to pay interest for wrongful availment of Cenvat Credit which has been reversed before utilization by the appellant in light of the decision of the Hon'ble High Court in the case of Bill Forge P. Ltd. (supra) which has been followed by co-ordinate bench in CCE Raipur Vs. M/s. Sharda Energy and Minerals Ltd. 2013 (291) ELT 404 (Tri.-Delhi) and in Commissioner of C.Ex. Allahabad Vs. Balrampur Chini Mills Ltd. 2014 (300) ELT 449 (Tri.Delhi).
With these observations, the impugned order is set aside and the appeal is allowed with consequential relief if any by holding that the appellants are entitled to avail Cenvat Credit and not liable to pay interest as demanded. Consequently, the penalties are not leviable.

Decision:-Appeal allowed.

Comment:-The essence of this case is assessee is entitled for input service credit on towers and cabin, which have been used by them for providing output service under the category of 'Business Auxiliary Service'.

Prepared By: Hushen Ganodwala

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