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    <title>2022 (10) TMI 583 - ALLAHABAD HIGH COURT</title>
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    <description>Purposive interpretation of the post-harvest storage infrastructure exemption under Notification No. 25/2012-ST extended it to construction and allied works such as roads, toilets and related facilities supporting agricultural produce storage at a mandi. Those works were treated as part of the underlying infrastructure necessary for post-harvest use, so the exemption applied. The Mandi Samiti&#039;s functions were also characterised as regulatory and public in nature, not commerce, industry or business, so its activities could not be treated as commercial to deny the exemption. The exemption for the works executed for the Mandi Samiti was therefore upheld.</description>
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      <description>Purposive interpretation of the post-harvest storage infrastructure exemption under Notification No. 25/2012-ST extended it to construction and allied works such as roads, toilets and related facilities supporting agricultural produce storage at a mandi. Those works were treated as part of the underlying infrastructure necessary for post-harvest use, so the exemption applied. The Mandi Samiti&#039;s functions were also characterised as regulatory and public in nature, not commerce, industry or business, so its activities could not be treated as commercial to deny the exemption. The exemption for the works executed for the Mandi Samiti was therefore upheld.</description>
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