Strict construction of exemption notifications bars concessional treatment unless every condition is satisfied by the assessee.

The exemption or abatement claim under Notification No. 30/2012-ST for manpower supply failed because the service recipients were Government hospitals and charitable organisations, while the relevant reverse charge entry applied only where the recipient was a business entity registered as a body corporate. The notification was held to require strict compliance, and the appellant bore the burden of proving that every condition was met. The alternative classification plea was also rejected because it had not been raised at the original stage and could not be introduced later through additional documents. The demand, interest and penalty were sustained.

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Issues: Whether the appellant was entitled to exemption or abatement under Notification No. 30/2012-ST for manpower supply services provided to Government hospitals and charitable organisations.

Analysis: The service recipients were Government hospitals and charitable organisations, whereas the relevant reverse charge entry under Part I(A)(v) of Notification No. 30/2012-ST applies only where the recipient is a business entity registered as a body corporate. The appellant therefore did not satisfy the essential condition for the concessional treatment. The exemption notification had to be construed strictly, and the burden lay on the appellant to establish that the claim fell within its terms. The plea regarding a different classification was also not accepted, as that ground had not been contested at the original stage and could not be raised belatedly through additional documents.

Conclusion: The appellant was not eligible for the claimed exemption or abatement, and the demand, interest, and penalty were sustained.

Ratio Decidendi: An exemption or concessional reverse charge entry must be strictly construed, and it can be granted only when every statutory condition is satisfied by the assessee.

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