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2022 (12) TMI 657

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..... e oil amounts to manufacturing? HELD THAT:- This issue has already been decided by the Tribunal in the aforesaid decision rendered in UEM India Limited [ 2021 (8) TMI 801 - CESTAT NEW DELHI ]. Thus, for all the reasons stated in the aforesaid order of the Tribunal, it would not be possible to sustain the order. Decided in favor of assessee. - SERVICE TAX APPEAL NO. 53724 OF 2018 - FINAL ORDER NO. 51133/2022 - Dated:- 23-11-2022 - MR. DILIP GUPTA, PRESIDENT AND MR. P.V. SUBBA RAO, MEMBER (TECHNICAL) Shri Kunal Agarwal, Advocate for the Appellant Dr. Radhey Tallo, Authorised Representative of the Respondent ORDER This appeal is directed against the order dated August 31, 2018 passed by the Commissioner, CGST .....

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..... include construction of STPs, ETPs, and laying of sewage pipes, rendered to Government bodies and other entities. The appellant filed a detailed reply contesting the demand on the ground that the services rendered by it were exempt by virtue of a Notification dated 20.06.2012 that was issued in exercise of the powers conferred by section 93(1) of the Finance Act. 5. The demand of service tax, where the services were rendered to Governmental authorities, was dropped by the Commissioner on the basis of the exemption available under Serial No. 12 of the aforesaid Notification dated 20.06.2012. However, demands in respect of three entities were confirmed and the benefit claimed by the appellant under Serial No. 13(d) of the said Notificatio .....

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..... 8. The three services, in respect of which the demands were confirmed, are tabulated below: S. No. Service Recipient Activity undertaken by the appellant Service Tax (in Rs.) 1. ONGC Assam Construction of ETPs in the oil fields of ONGC, registered under the Mines Act, 1952 26,49,982 2. ONGC Ahmedabad 2,06,54,736 3. National Building Construction Company Construction of Sewage Treatment Plant 1,74,839 7. An appeal, being ST/5029 .....

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