Does "Works Contract Service" Tax Exception for Railways Apply Only to Government? Ownership and Operation Under Scrutiny.

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....Works contract service - scope of the term Railways - stand of the tax authorities that the admitted exception of ‘railways’ was restricted to activities engaged in connection with railway undertakings of the Government - The exclusion of ‘metro’ or ‘monorail’ has occurred only after the period of dispute and therefore does not concern us. - Even where the ownership does not vest in the government, the operation of such railways is under special enactment which are not excluded from the sphere of the expression ‘railways’. - AT....