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Issues: Whether the activity of erection, commissioning or installation service rendered in connection with transmission and distribution of electricity was covered by the exemption or immunity notifications and therefore not liable to service tax, interest, and penalties.
Analysis: The Notifications granted immunity or exemption to services relating to transmission and distribution of electricity. The expression "in relation to" was applied in its wide sense to cover activities having a direct and proximate nexus with transmission or distribution of electrical energy. Services connected with providing infrastructure or facilitating transmission were treated as falling within the protective scope of the notifications.
Conclusion: The taxable service in question was held to be covered by the exemption and immunity notifications, and no service tax was payable.