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Respondent provided services to PGCIL for electricity transmission infrastructure, exempt under Notification 11/2010-ST. Hire charges rightly excluded as department failed to prove retention of effective control. Demand reinstated for parking construction for MCD, being commercial activity despite MCD's governmental status. Department precluded from raising new ground of 'site preparation services' at appeal stage. CESTAT allowed appeal partially.
Respondent provided services to PGCIL for electricity transmission infrastructure, exempt under Notification 11/2010-ST. Hire charges rightly excluded as department failed to prove retention of effective control. Demand reinstated for parking construction for MCD, being commercial activity despite MCD's governmental status. Department precluded from raising new ground of 'site preparation services' at appeal stage. CESTAT allowed appeal partially.
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