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Issues: Whether the activities of detailed engineering survey, cadastral survey, soil investigation, drawing and submission, and allied survey work were taxable as consulting engineering services during the relevant period.
Analysis: The activities undertaken by the assessee were examined on their nature and found to be survey-related functions, not the rendition of advice, consultancy or technical assistance by a qualified engineer in the course of consulting engineering. The record also showed that the levy on survey and map making was introduced only later by amendment, indicating that such work was not covered by the existing taxable entry for the relevant period. The appellate findings were accepted by the Tribunal, and no contrary material was shown to establish legal infirmity in that conclusion.
Conclusion: The activities were not liable to service tax under consulting engineering services for the relevant period, and the challenge by the revenue failed.