Cannot recharacterise a composite transaction into a works contract

The Tribunal rejects a revenue attempt to recharacterise a composite transaction into a works contract merely to trigger higher tax liability. It affirms that where the assessee has correctly segregated goods and services, paying VAT on goods and service tax on the service component, such treatment must be respected. 

The ruling reinforces the principle that classification must follow substance and factual execution rather than departmental reinterpretation. It also underscores the continued relevance of Notification 12/2003-ST in excluding the value of goods from taxable service.