2010 (12) TMI 12

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....e judgment and order dated 23.3.2009 passed by the Division Bench of the Bombay High Court setting aside and quashing the notices issued by the appellant herein to the Members of the respondent Association by holding that the entry contained in Section 65(105)(zzzy)of the Finance Act, 1994 does not include services provided by the Members of the respondent - Indian National Shipowners Association.....

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....des that any services provided to any person, by any person in relation to mining of mineral, oil or gas would be taxable. Counsel appearing for the respondent no.1 as also respondent no.3 Oil and Natural Gas Commission have submitted that the aforesaid interpretation sought to be given by the counsel appearing for the appellant is misplaced for the simple reason that the services rendered by the ....

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....ng in offshore.   E) To carry out routine surveillance in offshore for safety and security reasons   F) Standby at SBM tankers in offshore.   G) To assist in nmooring (sic) daughter vessel to mother vessel and securing to SBM in case of AHTSs.   H) To carry out any other field work which may be within the natural capabilities of the chartered vessel, as instructed b....

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....nto by them with the ONGC. None of the aforesaid entry in the Schedule could be strictly said to be a service rendered in relation to mining of mineral, oil or gas. Therefore we find justification in the findings arrived at by the High Court to the aforesaid extension. The nature of work which are set out in the Schedule at P.200 of the Paper Book cannot be said to be even remotely connected and i....