Classification of service— In the instant case, the appellant M/s. Oswal Industries Limited, has submitted that they are engaged in providing Naturopathy treatment since last 6 years. It is one of the largest Naturopathy Centers in India, and offers AYUSH approved treatments of Naturopathy, Ayurveda, Yoga including Meditation, Physiotherapy and special Therapy. It also provides Advanced Hydrotherapy and Heat Treatment like Stone Therapy.

The issue raised in the present case is whether the appellant is eligible to get the benefit of Sr. No. 74 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 and corresponding Notification No. 12/2017-State Tax (Rate) dated 30.06.2017 (the Central Tax (Rate) Notification referred to includes the reference to corresponding State Tax (Rate) Notification also).

The appellant has submitted that it had been availing exemption from Service Tax as per Sr. No. 2(i) of Notification No. 25/2012-Service Tax and referred to letter F.No. V/ST-Div/Nimba/2014-15 dated 10.03.2015 of the Deputy Commissioner, Central Excise, Kalol Division.

Held that— This authority confirm the Advance Ruling by holding that M/s. Oswal industries ltd. is not eligible to get the benefit of Sr. No. 74 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 and corresponding Notification No. 12/2017-State Tax (Rate) dated 30.06.2017.