Service tax on autonmous bodies of the central government

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CA. Sidharth Sahni (Querist)
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09 August 2014 Dear All

I have a client who is a Civil Contractor. He is providing his services mainly to the local authority here. In the meanwhile, he was also allotted contract from CSIO and IMTECH, units of CSIR, an autonomous body formed by the Department of Scientific and Industrial Research, Central Government.

In light of ST Notification No. 25/2012 dated June 20, 2012, services provided for Non commercial civil structure for Government and Local Authorities are exempt from service tax.

My query is, will the service provided by my client to CSIO and IMTECH fall under the above notification and be exempt from ST or not

Your views in this regard will be highly appreciated.

Regards
CA. Sidharth Sahni

CA. Sidharth Sahni

CA. Sidharth Sahni (Querist)
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12 August 2014 Hi

Can anyone please help me out with this thing please

Regards
CA. Sidharth Sahni

CA. Sidharth Sahni

CA. Sidharth Sahni (Querist)
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18 August 2014 Still waiting for your precious comments and knowledge.

Aashok Kumar Sharma online

Aashok Kumar Sharma online

(Expert)
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24 July 2025 Good question! Here's a clear explanation regarding **service tax exemption for services provided to autonomous bodies of the central government like CSIO and IMTECH (units of CSIR):**

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### Context:

* **Notification No. 25/2012-ST dated 20th June 2012** exempts services related to construction of **non-commercial civil structures** for the **Government, local authorities, or a government authority** from service tax.
* The key is whether CSIO and IMTECH qualify as "Government," "local authority," or a "government authority" for the purposes of this exemption.

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### Analysis:

* **CSIO and IMTECH are autonomous bodies under CSIR**, which is an organization under the Department of Scientific and Industrial Research, Ministry of Science & Technology, Government of India.
* Although autonomous, they **function under the Central Government**, and are generally considered government authorities for service tax purposes.
* Courts and tax authorities have generally treated similar autonomous bodies as **government authorities** for service tax exemption on non-commercial civil structures.
* Therefore, services rendered by your client to CSIO and IMTECH **should qualify for exemption under Notification No. 25/2012** if:

* The contract relates to **non-commercial civil structures** (like buildings, roads, bridges, etc.).
* The services are not for any commercial purpose (e.g., no commercial leasing, no profit-oriented structures).

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### Conclusion:

* **Yes, the services provided by your client to CSIO and IMTECH for non-commercial civil structures will likely be exempt from service tax under Notification No. 25/2012-ST.**
* However, if the service pertains to commercial structures or commercial activities, service tax will be applicable.

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### Recommendation:

* Maintain clear contract documentation stating the nature of the structure and purpose.
* If in doubt, you may seek a **formal advance ruling** or consult a service tax expert for confirmation.

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If you want, I can help draft a formal opinion letter for your client or suggest points to include in a service tax audit response related to this. Would you like that?

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