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2015 (3) TMI 1106 - AT - Service TaxTransmission of electricity or distribution - Exemption under Notification No. 45/2010-ST dated 20.07.2010 till 2010 and subsequently under Notification No. 11/2010-ST dated 27.02.2010 - Held that:- There is no contrary finding that manpower supply service has not been provided to a transmission and distribution company. There is no detail available as to how the service provided by the appellants has to be treated as the one provided prior to transmission and distribution of electricity. Notification No. 45/2010 exempts all the services rendered in relation to transmission and distribution of electricity and there is no distinction made prior to commencement of transmission or distribution subsequently. It is quite clear that in this case services are provided to M/s. APCPDCL which is engaged only in transmission of electricity and therefore services provided by them have to be considered as the one provided for transmission not distribution. Under these circumstances we consider that the appellants clearly are eligible for the benefit of Notification No. 45/2010. In view of the fact that the issue involved has been considered in detail and there is nothing left to look at, it would be appropriate to allow the appeal itself at this stage rather than keeping the matter pending for years before this Tribunal. - Decided in favour of assessee.
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