In the case of HCL Infosystems vs CC&CE, Noida, Delhi CESTAT held that Trading activity is neither ‘service’ nor ‘exempted service’ for the period prior to April 2011. CESTAT stated that explanation added to Rule 2 of CENVAT Credit Rules (CCR), 2004 vide. Notification No. 3/2011-CE clarified that exempt-ed services include trading.