1. The appeal is directed against the finding that the appellant is rendering ‘cargo handling services’ to M/s Lafarge India (P.) Ltd. in regard to cement manufactured by M/s Lafarge India at its cement plant at Gopal Nagar and that service tax is required to be paid on the amounts received for rendering the said cargo handling services. Present appeal describes the service rendered as under :

"The appellants provide labour for managing various points in the mechanized process of packing and loading of cement bags. Lafarge India has installed machines for packing of cement in HDPE bags and for automatically loading of these bags into trucks and wagons through a conveyer system. The labourers provided by the appellants simply stand at different places in the mechanized packing process. One person feeds cement bags onto the machine which captures these bags and pours cement into bags and the bags get sealed automatically. After this, the bags fall onto the conveyer system which takes these bags to the exist point that goes right into the truck or wagon. At the exit point, the labourers simply give a helping push to the bag whenever necessary, so that it falls in place and the bag