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TMI Blog2025 (2) TMI 902X X X X Extracts X X X X X X X X Extracts X X X X ..... s any service rendered to Government in relation to public health.
The services provided by the Appellants, involving the transportation of health professionals for the National Health Mission, fell within the exemption under Notification No.25/2012-ST.
The Original Authority was correct in holding that the services rendered by the Appellants are not taxable - The impugned order is set aside and the appeal is allowed. X X X X Extracts X X X X X X X X Extracts X X X X ..... - (a) Shapoorji Paloonji & Company Pvt. Ltd. V/s C.C., C.EX. & S.T., Patna [2016 (42) S.T.R. 681 (Pat.) (b) Commr. of C.Ex. & Cus., Patna V/s Advantage Media Consultant [2008 (10) S.T.R. 449 (Tri.-Cal.] (C) Commr. C.Ex. & ST, Bhavnagar V/s M J Solanki [ST/10664/2020 (Tri.-Ahmd.)] 4. Shri Santosh Kumar learned Authorized Representative reiterates the findings of the impugned order and submits that in terms of Notification No.25/2012-ST services provided by way of transportation of a patient in an ambulance are exempted. The said exemption is not available to vehicles supplied for transportation of Doctors and paramedics. 5. Heard both sides and perused the records of the case. 6. We find that the Appellants have provided vehicles fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are engaged in providing services related to public health. The para-medic personnel, etc. provided by the respondent to said Hospitals / Health Centre have worked under the supervision of authorized Medical Practitioner i.e. Medical Superintendent, Medical Officers of the Hospital, health centre etc. Thus the Medical Superintendent, Medical Officers of the Hospital and Health centres who provided service by way of public health to the said government hospital and health centre run by the government in the capacity of government employee and the para-medics, etc, provided by the respondent who worked in the same hospitals/ health centres are their subordinates and carried out their instructions in connection with public health, were all pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... conclusion reached by the Ld. Commissioner in the impugned order before us. In our view, impugned order is correct, legal and does not suffer from any infirmity." 8. We find that the Tribunal has already interpreted the word "any activity" in a wider perspective for the purpose of Notification No.25/2012. The Appellants have provided vehicles for transportation of Doctors, Paramedics and health workers for carrying out their day to day work in the National Health Mission. Therefore, the provision of vehicles to personnel engaged in execution of National Health Mission etc. by the Appellant is to be construed as any service rendered to Government in relation to public health. Therefore, we are of the construed opinion that the same is cover ..... X X X X Extracts X X X X X X X X Extracts X X X X
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