Debate on Service Tax Recovery for Railway Siding Construction Hinges on "Railways" Definition in Section 65(105) of Finance Act 1994.

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....Recovery of service tax - construction of a railway siding track works - scope of the term railways - The ‘constructions’ excluded from taxability under both the entries in section 65(105) of Finance Act, 1994 are, plainly, unqualified. The legislative intent, therefore, cannot be circumscribed by encroachment, or restrictive interpretation, ventured upon by tax authority. - AT....