https://www.taxtmi.com/caselaws?id=789084 An exemption under Notification No. 30/2012-ST for manpower supply applied only where the recipient was a business entity registered as a body corporate; supply to Government hospitals, Government departments and charitable organisations did not meet that condition. The exemption had to be strictly construed, and the appellant bore the burden of proving entitlement, so the demand was sustained. Additional documents and a new classification plea that the service was cleaning services were not entertained at the appellate stage because they were outside the original adjudication and could not be introduced to fill gaps in the earlier case. The demand, penalty and appeal failure were upheld. en-us Thu, 02 Apr 2026 00:00:00 +0530 Fri, 03 Apr 2026 08:49:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789084 An exemption under Notification No. 30/2012-ST for manpower supply applied only where the recipient was a business entity registered as a body corporate; supply to Government hospitals, Government departments and charitable organisations did not meet that condition. The exemption had to be strictly construed, and the appellant bore the burden of proving entitlement, so the demand was sustained. Additional documents and a new classification plea that the service was cleaning services were not entertained at the appellate stage because they were outside the original adjudication and could not be introduced to fill gaps in the earlier case. The demand, penalty and appeal failure were upheld. Case-Laws Service Tax Thu, 02 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789084