2023 (11) TMI 257

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.... from the records that during the period from April 2013 to September 2013, the appellant provided the following services to Municipal Corporations/ Municipal Councils: Sr. No. Project of Detail Nature of work Taxable value from April, 2013 to September, 2013 1 Municipal  Counsil, Sehore (M.P.) Work of providing laying & jointing including excavations of pipe trenches, bedding, refilling, testing, commissioning & trial run. 70,85,926/- 2. Municipal Corporation, Rewa (M.P.) Work order for providing, laying & jointing including excavation pipe bedding, refilling testing, commissioning and trial run. 1,18,14,721/- 3. ....

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....e show cause notice on merits. The Commissioner, after examination of the work orders issued to the appellant by the Municipal Corporations/ Municipal Councils, held that the work undertaken by the appellant would fall within Explanation (e) of the definition of "works contract services" under section 65 (105) (zzzza) of the Finance Act, 1994 [the Finance Act]. 5. Shri Jatin Mahajan, learned counsel appearing for the appellant submitted that since the period involved in the present appeal is from April 2013 to September 2013, the issue would have to be examined in terms of the Notification No. 25/2012 dated 20.06.2012 [(Notification dated 20.06.2012]  which exempted certain taxable services from the whole of the service tax leviable....

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....Act, 1994 (32 of 1994) (hereinafter referred to as the said Ac) and in supersession of notification number 12/2012-Service Tax, dated the 17th March, 2012, published in the Gazette of India. Extraordinary, Part II, Section 3, Sub-section (i) vide number G.S.R. 210(E), dated the 17th March, 2012, the Central Government, being satisfied that it is necessary in the public interest so to do, hereby exempts the following taxable services from the whole of the services tax leviable thereon under section 66B of the said Act, namely:- 12. Services provided to the Government, a local authority or a governmental authority by way of construction, erection, commissioning, installation, completion, filling out, repair, maintenance, renovation, ....