Smt. Archana Wadhwa, Judicial Member - The appellants are registered as service providers under the category of Management, Maintenance or Repair Service and Erection, Commissioning and Installation Service . They provide these services to M/s. Andhra Pradesh Southern Power Distribution Company owned by the Government of Andhra Pradesh for providing power distribution to Kadapa, Tirupathi, Guntur and Ongole districts. The appellant was discharging service tax on the service portion of the contract and was reflecting the same in their ST-3 returns, regularly filed with the Revenue.

2. Demands were raised against the appellant for the period from 2007-08 to 2012-13 (till 30.11.2012) by way of issuance of show-cause notice dated 20.4.2013 alleging that they were required to pay service tax on the entire contracted value, inclusive of the value of the materials.

3. During adjudication, appellant took a stand that in any case up to 21.6.2010, they were entitled to exemption under Notification No.45/2010 ST dated 20.7.2010 issued in terms of Section 11C vide which all taxable services rendered relating to the distribution of electricity were exempted from the levy of service tax up to