Service tax exemption on services in SEZ to Main contractors who are neither SEZ Unit nor SEZ developer

B T Patel & Co Vs C.C.E. & S.T.-Rajkot (CESTAT Ahmedabad) CESTAT find that the learned Commissioner in denying the exemption by made a strict interpretation of language of the notification no. 4/2004-ST dated 31.03.2004 though as per the language of the exemption of service provided to SEZ developer or to the unit in SEZ. In the present case admittedly though the service was provided in SEZ but the service recipient who are the main contractor are neither developer of SEZ nor have their unit in SEZ therefore, apparently it appears that the service in terms of notification may not be el...