Per Mr. AJAYAN T.V.

Sundaram Fasteners Ltd., the appellant herein, has preferred these appeals, details of which are given below, aggrieved by the respective Orders in Appeal of the Commissioner Appeals:

2. The relevant facts are that the Appellant is a manufacturer of automative fasteners registered for providing Consulting Engineer Services, (CES), Business Auxiliary Services, (BAS), Testing Inspection and Certification Services (TICS) and Intellectual Property Services (IPS). During the scrutiny of the appellant records, it was found that the appellant had incurred expenses towards warehouse related services in USA and have also realized lease income for renting out their windmills to their group Company M/s. Sundaram Non-conventional Energy Systems Ltd. for use in their project for generation of power.

3. The Department asked the Appellant as to the nature of activity of the service providers abroad pertaining to the warehouse related services in USA. The Appellant clarified that the service providers abroad cleared the goods from the Customs, transported from the port of arrival to the Warehouse, stored, packed and delivered to the intended customers of the Appellant in that coun