Government Construction Projects Denied Tax Exemption; Oil Fields Not Classified as Factories u/s Definitions.

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....Commercial or industrial construction service - services rendered to Government bodies and other entities - benefit exemption has been denied for the reason that the services have been rendered in the factory area - Scope of 'Factory' - the premises where the post-production processes take place towards making the produce commercially viable would qualify as a factory - the oil fields of ONGC, where only extraction of crude oil takes places, would not qualify as a ‘factory’. - The Commissioner committed an illegality in denying the benefit of the Notification dated 20.06.2012 at Serial No. 13(d) to the appellant for ETPs constructed for ONGC and the STPs constructed for NBCC - AT....