Exemption for services linked to electricity transmission and distribution upheld, covering related manpower supply services.

Services rendered to a transmission and distribution company were treated as covered by the exemption for services in relation to transmission and distribution of electricity. The analysis found no clear basis for denying the benefit and no contrary finding showing that the manpower supply service fell outside the notification's scope. The exemption was applied without distinguishing between services provided before the commencement of transmission or distribution and those provided later. The appellant was therefore entitled to the exemption notifications, and the tax demand could not be sustained.

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Issues: Whether the appellant was entitled to exemption from service tax for services rendered in relation to transmission and distribution of electricity under the relevant notifications.

Analysis: The services in dispute were stated to have been rendered to a transmission and distribution company. The earlier authority had not recorded a clear basis for denying the benefit of the exemption, and no contrary finding was available to show that the manpower supply service was outside the scope of services rendered in relation to transmission and distribution of electricity. The exemption notification was treated as covering services rendered in relation to transmission and distribution of electricity without drawing a distinction based on whether the service was provided before commencement of transmission or distribution. On that basis, the services were held to fall within the exemption.

Conclusion: The appellant was held entitled to the benefit of the exemption notifications and the demand could not be sustained.

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