Exemption for electricity transmission infrastructure construction upheld; sub-station and related works fell within the notification.

Construction of a sub-station and SDO office for the electricity department was treated as activity connected with transmission of electricity, and the expression "for transmission of electricity" was read to cover construction and allied works for transmission and distribution infrastructure, including sub-stations. On that basis, exemption under Notification No. 11/2010-ST was held applicable to the appellant's activity, and the service tax demand was found not sustainable.

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Issues: Whether the appellant was entitled to exemption from service tax under Notification No. 11/2010-ST dated 27.02.2010 for construction of sub-station and SDO office for the electricity department, and whether the confirmed demand could be sustained.

Analysis: The construction activity was undertaken for the electricity department and was connected with transmission of electricity. The Tribunal relied on its earlier decisions holding that the expression "for transmission of electricity" covers construction and allied activities relating to transmission and distribution infrastructure, including sub-stations. On that basis, the benefit of the notification was held to extend to the appellant's activity.

Conclusion: The service tax demand was not sustainable and the appellant was entitled to the exemption.

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