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Construction of Coronation Park Amenities Exempted from Service Tax: CESTAT rejects Dept's appeal [Read Order]

The respondent claimed that the Coronation Park is a historical monument and is eligible for exemption.

Construction of Coronation Park Amenities Exempted from Service Tax: CESTAT rejects Depts appeal [Read Order]
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The Customs, Excise and Service Tax Appellate Tribunal (CESTAT), New Delhi Bench, rejected the department’s appeal and held that the construction of Coronation Park amenities is exempted from Service Tax. Also Read:Relief for Bharat Electronics: CESTAT Upholds Shipping Bill Conversion Beyond 3 Months, CBEC Circular Time Limit Not Binding [Read Order] The facts are that...


The Customs, Excise and Service Tax Appellate Tribunal (CESTAT), New Delhi Bench, rejected the department’s appeal and held that the construction of Coronation Park amenities is exempted from Service Tax.

The facts are that the respondent, M/s. Ajab Singh & Co., was registered under the taxable category of ‘Renting of Immovable Property Services’. The respondent was engaged in execution of construction works for DDA. The scope of work executed by the respondent/contractor included construction and repair of roads, construction of parking facilities, upgradation and renovation of residential houses and construction of residential complexes.

A show cause notice was served on 22.11.2013 for the Financial Year 2011-12 whereby demand along with interest under Section75 and penalties under Section 76, 77 and 78 of the Finance Act was proposed. The Commissioner confirmed some of the demand under the taxable category of Works Contract Service.

Ajab Singh & Co were represented by A.K. Batra and Sakshi Khanna while Mihir Ranjan (Special Counsel) and Rajeev Kapoor (Authorized Representative) presented arguments for the Revenue Department.

The Revenue argued that the construction of roads may be covered under exemption but the construction of the International Centre and Restaurant Building was not exempted as they are commercial in nature. The respondent claimed that the Coronation Park is a historical monument and is eligible for exemption.

The tribunal considered the exemption in the mega Notification 25/2012-ST dated 20.06.2012 and held that the historical site is eligible for exemption. Further, it was held that the provision of parking in such parks is for public utility and charging nominal charges does not make it commercial.

Relying on M/s Road Infrastructure Development Company of Rajasthan Ltd v. Commissioner, Jaipur, the bench of Binu Tamta (Judicial Member) and Hemambika R. Priya (Technical Member) rejected the appeal by the department and allowed the exemption contained in SI. No. 12 of Notification No. 25/2012.

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M/s. Ajab Singh & Co. vs Principal Commissioner of Service Tax , 2026 TAXSCAN (CESTAT) 375 , Service Tax Appeal No. 54194 of 2015 , 1 April 2026 , Shri A.K.Batra, Ms. Sakshi Khanna , Shri Mihir Ranjan, Shri Rajeev Kapoor
M/s. Ajab Singh & Co. vs Principal Commissioner of Service Tax
CITATION :  2026 TAXSCAN (CESTAT) 375Case Number :  Service Tax Appeal No. 54194 of 2015Date of Judgement :  1 April 2026Coram :  MS. BINU TAMTA, MS. HEMAMBIKA R. PRIYACounsel of Appellant :  Shri A.K.Batra, Ms. Sakshi KhannaCounsel Of Respondent :  Shri Mihir Ranjan, Shri Rajeev Kapoor
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