(1.) LD . Counsel Shri Narsimhan submits that when the appellant operated under a contract entered into between the State Govt. of Madhya Pradesh and the appellant on 9 -10 -2001 for carrying out following scope of activity, it was misconceived to be "Business Auxiliary Service" by Revenue.
(2.) THE activities carried out as above squarely falls within sub -clause (iv) of Section 65(19) of Finance Act, 1994. When the appellant procured goods as input for the State of Madhya Pradesh. Therefore, the primary activity of issuance of Smart Card with readable chip falls in that category of service. There is no legal infirmity in the adjudication order.
(3.) HEARD both sides and perused the records.