https://www.taxtmi.com/caselaws?id=444525 An exemption notification for construction services was construed according to its plain language: the definition of "governmental authority" in clause 2(s) contained two independent alternatives, and the 90% participation requirement applied only to the second alternative, not to an authority or body set up by an Act of Parliament or a State Legislature. Because the text was clear and unambiguous, it could not be rewritten by treating "or" as "and" or by extending the qualifying phrase beyond its proper clause. Educational institutions established under central enactments were therefore covered by the definition, and construction services rendered to them qualified for exemption from service tax. en-us Fri, 13 Oct 2023 00:00:00 +0530 Fri, 08 Aug 2025 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444525 An exemption notification for construction services was construed according to its plain language: the definition of "governmental authority" in clause 2(s) contained two independent alternatives, and the 90% participation requirement applied only to the second alternative, not to an authority or body set up by an Act of Parliament or a State Legislature. Because the text was clear and unambiguous, it could not be rewritten by treating "or" as "and" or by extending the qualifying phrase beyond its proper clause. Educational institutions established under central enactments were therefore covered by the definition, and construction services rendered to them qualified for exemption from service tax. Case-Laws Service Tax Fri, 13 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444525