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CESTAT determined that the common effluent treatment plant's activities are exempt from service tax under Section 145 of the Finance Act, 2012, retrospectively from 16.06.2005 to 30.06.2012, and subsequently under Notification No. 8/2017-ST from 01.07.2012. The tribunal held that the entity's water treatment services do not constitute Business Auxiliary Service but qualify as a club or association service, thus shielding it from service tax liability. The treatment of effluent water does not represent processing of goods, and the government-subsidized plant's operations are exempted from taxation. The appeal was consequently allowed.
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