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2023 (10) TMI 352 - AT - Service TaxExemption from service tax - Transmission and distribution of electricity - work executed as sub-contractor, on back to back basis, allotted by the main contractor - benefit of N/N. 45/2010-ST dated 20.07.2010 denied - Commercial or Industrial Construction service (CICS) - work being – earth work, laying of concrete, shuttering & rod bending. HELD THAT:- There is no ambiguity in the exemption granted for services provided to distribution and transmission companies vide Notification No. 45/2010-ST, and the reliance placed by the Revenue on the clarificatory Circular dated 01.07.2010 is misplaced. Further, it is found that there is no reference of earlier Notification No. 11/2010-ST in the Notification No. 45/2010- ST and hence, attempt by the Revenue to read the exemption notification with the previous notification, is also misplaced. There is no error in the Impugned Order - Appeal of Revenue dismissed.
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