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The Customs, Excise and Service Tax Appellate Tribunal held that the construction services provided by the respondent to the Institute of Chartered Accountants of India (ICAI), Rajkot Municipal Corporation, and Gujarat Industrial Development Corporation (GIDC) for constructing an engineering college were exempt from service tax. ICAI, being established under an Act of Parliament and under the control of the Government of India, qualifies as a governmental authority. Municipal corporations are specifically exempted under the relevant notification. GIDC, being a department of the state government, is also a governmental authority, and the construction of an engineering college is an educational activity, further exempting it. Therefore, the construction services provided to these entities were rightly exempted by the Commissioner, and the Revenue's appeal was dismissed.
The Customs, Excise and Service Tax Appellate Tribunal held that the construction services provided by the respondent to the Institute of Chartered Accountants of India (ICAI), Rajkot Municipal Corporation, and Gujarat Industrial Development Corporation (GIDC) for constructing an engineering college were exempt from service tax. ICAI, being established under an Act of Parliament and under the control of the Government of India, qualifies as a governmental authority. Municipal corporations are specifically exempted under the relevant notification. GIDC, being a department of the state government, is also a governmental authority, and the construction of an engineering college is an educational activity, further exempting it. Therefore, the construction services provided to these entities were rightly exempted by the Commissioner, and the Revenue's appeal was dismissed.
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