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    <title>2025 (9) TMI 679 - GAUHATI HIGH COURT</title>
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    <description>Work orders containing both construction of roads and irrigation work and supply of workforce were treated as involving distinct components, and the exemption under Notification No. 25/2012-ST was found applicable only to the construction element. The levy was held to relate to the manpower supply component, while the contention that tax was imposed on the entire contract value raised disputed questions of fact. The High Court declined to interfere in writ jurisdiction under Article 226, holding that it would not reappreciate factual findings as an appellate forum, particularly where a statutory appeal was available. The writ petition was dismissed, with liberty to pursue the appeal against the order-in-original.</description>
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      <link>https://www.taxtmi.com/caselaws?id=778190</link>
      <description>Work orders containing both construction of roads and irrigation work and supply of workforce were treated as involving distinct components, and the exemption under Notification No. 25/2012-ST was found applicable only to the construction element. The levy was held to relate to the manpower supply component, while the contention that tax was imposed on the entire contract value raised disputed questions of fact. The High Court declined to interfere in writ jurisdiction under Article 226, holding that it would not reappreciate factual findings as an appellate forum, particularly where a statutory appeal was available. The writ petition was dismissed, with liberty to pursue the appeal against the order-in-original.</description>
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