Where assessee was doing repair work of transformers, which were used for transmission and distribution of electricity, said activity would fall in ambit of ‘in relation to transmission and distribution of electricity’.

The exemption provided in Notification No. 45/2010-ST, dated 20-7-2010 appears to be for all taxable services relating to transmission of electricity. On this count, there are plethora of judgments, wherein it has been held that erection, commissioning and installation comes within the ambit of the expression ‘in relation to’ Going by the ratio of the judgments, the activity undertaken by the assessee would fall in the ambit of ‘in relation to transmission of electricity’ in terms of Notification No. 45/2010, dated 20-7-2010, as there is a clear nexus between the service rendered by the assessee and transmission and distribution of electricity. Therefore, we hold that the exemption contained in the said Notification is squarely applicable to the appellants.

Citation: [2018] 96 taxmann.com 548 (Bangalore – CESTAT)