Here, Person doing fabrication is service receiver
And
Exporter is service receiver
There can be 2 cases
-
Service is in nature of supply of labor
It means Service Provider only provided labor which works as per direction of exporter
In this case, Service is covered in Manpower service and taxable
Note :- In Manpower service, Reverse charge is applicable if Service provider is a Non Co and Service Receiver is a Company
-
Service is in nature of supply of Job worker
In this case, Service Provider is responsible for whole work and service receiver is not concerned about the labor
In this case, excise will be charged and not service tax.