Construction Services for Staff Quarters Exempt from Tax u/s 65(91a); No Commercial Elements Involved.

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....Taxability - Construction of residential complex for personal use - staff quarters/ said residential units - work done by the sub-contractor - The services provided by the appellant to M/s. PGCIL are covered under the exclusion part of said sub clause (iii) of section 65(91a) of the Act, M/s. PGCIL being ‘a person’ of the said sub clause and appellant being the ‘any other person’. Hence, irrespective the impugned service is the service of construction of residential complex but is the one as stands exempted from the tax liability due to the exclusion given to the residential complex which is meant for personal use as residence by the person who directly engaged the service provider and that no element of commerce or industry is involved - AT....