Service tax on hal

Please refer to Explanation 1 of GENERAL EXEMPTION NO. 26 on Exemption to goods manufactured in a factory on job work for use by specified undertakings who supply final goods to the Ministry of Defence. [Notifn. No.70/92-CE dt.17.6.1992 as amended by Notifn. Nos. 140/94, 66/95, 96/95 and 7/98]. The same is produced below for ready reference:

"Explanation I - For the purposes of this notification, the expression "job work means procesing or working upon of raw materials or semi-finished goods supplied to the job worker, so as to complete a part or whole of the process resulting in the manufacture or finishing of an article or any operation which is essential for the aforesaid process."

 While referring to the Explanations given in Notification no.8/2005 it seems that Service amounting to manufacture & cases where final goods are exempt are specifically excluded. Hence Service Tax would have to be paid.