Site formation / Site preparations Service tax

Sir,
Under works contract
siteprepartion/ site formation work
was executed I.e undersection 65 (105) zzza.
Dispute is there on deduction of
service tax whether it is 4.94%(40% of 12.36%)
or 12.36% (100% of 12.36%)
There were no construction activities.
Happened during 1994.


Which one is correct?
M.Radhakrishnan.