2018 (11) TMI 1471

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....appellant was engaged in providing construction service only for charitable institution i.e., Dharmasthala Manjunatheswara Educational Society and there was no other customers of the appellant. Appellant was constructing staff quarters, student hostel and then college library and the initial constructions were for construction of student hostel and staff quarters. Prior to negative list, there was clear exemption Notification exempting such construction for charitable institution and after the negative list, the appellant's client categorically informed that they are not liable to pay service tax on the ground that the building is an individual house as well as it is not for commercial purposes and being charitable organization, they were e....

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....at the activities carried out by her is not taxable as she was engaged in the construction of student hostel and staff quarters for a charitable institution, who was the only client of the appellant. He further submitted and placed on record the correspondences between the appellant and their customers whereby the appellant's customer has clarified to the appellant vide their letter dated 4.4.2013 that they are not liable to service tax as they fall in the definition of Trust and entitled to exemption under Notification No.25/2012-ST dated 20.6.2012. He further submitted that when the appellant received the letters from the Department thereafter the appellant paid the entire service tax along with interest at least two years before the summ....