Item No.- 14 10.03.2025 Rohan Court No. 2 IN THE HIGH COURT AT CALCUTTA Circuit Bench at Jalpaiguri WPA 447 of 2025 M/s Rural Unemployed Co-operative Labor Contract & Construction Society Ltd.

Versus Commissioner (Appeal) Office of the Joint Commissioner, Central GST & Central Excise & Ors.

Mr. Jagriti Mishra, Ms. Ananya Bhattacharya, Ms. Mrinmayee Das. … for the petitioner Mr. Dilip Kumar Agarwal, Mr. Bishwaraj Agarwal.

… for the respondent Nos. 1 & 2

1. Affidavit-of-service filed on behalf of the petitioner is taken on record.

2. Learned counsel representing the petitioner submits as follows. The petitioner did some labour contract job for the Government. Any such work, if done for the Government, is exempted from the ambit of service tax as per Clause 12 of the notification dated 28th June, 2012. The nature of work fully brought the petitioner within the ambit of such exemption. After the petitioner had appeared before the respondent authorities to explain a show cause, he duly submitted a list of such work orders and the nature of work that he did. Infact, the authority partly admitted to the fact that the petitioner was engaged in such work for the Government at paragraph 5.5.1 of