2019 (3) TMI 539 – AUTHORITY FOR ADVANCE RULING, MAHARASHTRA – TMI – Levy of tax – SGST/CGST Act – setting up of a comprehensive CCTV based city surveillance system – amount received for supply of services during the post GST period to the Government of Maharashtra (Home Department) as per the contract – Held that:- In the present contract, we find that the liability of the contractor-applicant does not end with the supply of goods but it extends till the successful testing, commissioning and also to maintenance of the system. The present contract in our view is a works contract as it involves provision of services and goods, but it is for us to decide whether it is works contract as defined under the GST Act cited supra. The term 'immovable property' has not been defined under the GST Act. However, there are plethora of judgments of the Hon. Supreme Court and the Hon. High Courts which have helped understand the term 'immovable property'.
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The set up of a comprehensive CCTV bas
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the Notifications applicable to the present case.
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Thus' Original Works' would mean ; all new constructions; all types of additions and alterations to abandoned or damaged structures on land that are required to make them workable; erection, installation etc. that results in increase in life and value of property . In the present case the work done by the applicant does not appear to be original works.
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In the present case, the contract is not related to any original work and is in the nature of composite supply of Works Contract – the activity of the applicant in the present case is nothing but a composite supply of Works Contract, not being original works and they will be covered under Sr. No. 3, item no. (ii) of Notification No. 11/2017 dated 28.06.2017 as amended by Notification No. 1/2018 dated 25.01.2018 and attract 18% GST (9% each of CGST and SGST). – GST-ARA- 90/2018-19/B-159 Dated:- 19-12-2018 – SHRI B. TIMOTHY, AND SHRI B. V. BORHADE, MEMBER PROCEEDINGS (under se
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ce to the CGST Act would also mean a reference to the same provision under the MGST Act. Further to the earlier, henceforth for the purposes of this Advance Ruling, a reference to such a similar provision under the CGST Act / MGST Act would be mentioned as being under the GST Act . 02. FACTS AND CONTENTION – AS PER THE APPLICANT The submissions, as reproduced verbatim, could be seen thus- Statement of relevant facts having a bearing on the question(s) on which advance ruling is required. 1. The Government of Maharashtra (for short GOM ) has envisaged to setup a comprehensive CCTV based City Surveillance System for the city of Pune and Pimpri-Chinchwad (hereinafter referred to as the Surveillance Project ). 2. The GOM published the Request for proposal (for sort' RFP') to seek services of a reputed IT firm as a System Integrator for Design, Development, Implementation & Maintenance of CCTV based Surveillance System For Pune and Pimpri-Chinchwad areas. Accordingly the Applica
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tachments and annexure thereto and all documents incorporated by reference therein; (c) 'Systems Integrator' means M/s. Allied Digital Services Limited interchangeably referred to as SI in the contract; and (d) 'RFP' means the Tender Published by GOM (Ref. No. ISS 1012/CR-7l/Spl-4) and the subsequent corrigenda/Clarifications issued. (e) 'GO Live' means the date on which the proposed solution becomes operational after successful conclusion of all acceptance tests to the satisfaction of GOM. (f) Deliverable means any action/output generated by the SI while discharging their contractual obligations. This would include feeds, analytics, information and all the other services rendered as per the scope of work and as per the SLAS. (g) Assets refer to all the hardware / Software / furniture / data / documentations / manuals / catalogs / brochures / or any other material procured, created or utilized by the SI or the GOM for the Pune Surveillance Project. 3) Term of th
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te of Successful Go Live and shall be subject to strict adherence of the respective SLAS. If the Systems Integrator is liable for any penalty/liquidated damages as per the SLAs (refer to the clause no. 7 of this agreement), the same shall be adjusted from quarterly payments due to the System Integrator. GOM will release the payment within 30 days of submission of valid invoice subject to the condition that invoice and ail supporting documents produced are in order and work is performed to the satisfaction of GOM. GOM shall be entitled to delay or withhold the payment of any invoice or part of it delivered by SI. where GOM dispute such invoice or part of it provided that such dispute is bonafide. The disputed amount shall be settled in Resolution of dispute. 6) Work Completion Timelines List of the broad activities to be carried out by the Systems Integrator and the timelines from the date of work Order are given in the table below. T stands for the date of issue of the Work Order. Sr.N
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ffice & Addnl. CP Office Viewing Center at Zone 1, Supply & Installation of equipments at corresponding Police Stations T + 21 weeks 11 Establishing connectivity for Zone I Cameras, Command Center & Police Stations T+23 weeks 12 Training and Capacity Building for the Police Personnel for Phase I T+25 weeks 13 FAT for Phase I cameras, Command / viewing Center Setup, Police Station Setups T + 26 weeks 14 FAT for Data Centers T + 26 weeks 15 Go Live for the 1 st Zone T + 26 weeks Phase II Operationalization at 2nd 3rd & 4th Zone 16 Supply, Installation of Cameras for 2nd, 3rd & 4th Zones T + 31 weeks 17 Development of the remaining viewing Centers, Supply & Installation of equipments at corresponding Police Stations T + 26 weeks 18 Establishing connectivity for Phase II Cameras, viewing Center, Police Stations T + 33 weeks 19 Training and Capacity Building for the Police Personnel for Phase II T + 35 weeks 20 FAT for phase II Cameras, Viewing Center Setup, Police S
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owned by the system integrator exclusively in terms of the delivery of the services as per this Agreement (hereinafter the Assets ) in proportion to their use & control of such Assets which will include all upgrades/enhancements & improvements to meet the needs of the project arising from time to time. b) Term Assets also refers to all the hardware / Software / furniture / data / documentations / manuals / catalogues / brochures / or any other maternal procured, created or utilized by the SI or the GOM for the Pune Surveillance Project. c) Maintain 3% of installed camera quantity as spare inventory at all times, for an types of cameras. d) Keep all the tangible Assets in good & serviceable condition (reasonable wear & tear excepted) &/or the intangible Assets suitably upgraded subject to the relevant standards as stated in of the RFP to meet the SLAs mentioned in the contract & during the entire term of the Agreement. 9) Provide a well-prepared documentation for
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, where the SI shall be designated as the loss payee' in such insurance policies; & SI shall be able to pay premium for the insurance policy & shall ensure that each & every policy shall keep updated from time to time. o) Ownership of the Assets shall vest with GoM on Go Live of the project. Ownership of any asset, created during the contractual period after go live, shall also vest with GOM upon creation of such asset p) Ensure the integration of the software with hardware to be installed and the current Assets in order to ensure the smooth operations of the entire solution architecture to provide efficient services to GOM of this project in an efficient and speedy manner. q) Obtain a sign off from GOM or its nominated agencies at each stage as is essential to close each of the above considerations. r) Ensure that the Mobile Vans mentioned in RFP shall be registered under the provisions contained u/s 39 of Motor Vehicle Act, 1988 in the name of GoM. s) Follow/observe t
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nto executable/installable product. Government of Maharashtra may permit the SI, right to use the customized software for any similar project being executed by the same SI, with payment of reasonable royalty to GoM for the same. (B) GOM has sovereign rights & nothing herein shall or will be construed or deemed to grant to t System Integrator any right, title, license, sub-license, proprietary right or other claim against or interest in to or under (whether by estoppels, by implication of otherwise) to the Intellectual Property Rights. Miscellaneous j) Personnel/Employees i. Personnel/employees assigned by System Integrator to perform the services shall be employees of System Integrator and/or its subcontractors, & under no circumstances will such personnel be considered as employees of GOM. System Integrator shall have the sole responsibility for supervision & control of its personnel & for payment of such personnel's employee's entire compensation, including sa
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on schedule & upon clearance of the personnel based on profile review & personal interview by GOM or its nominated agencies, within not later than 30 working days. System Integrator shall depute quality team for the project & as per requirements, GoM shall have the right to ask System Integrator to change the team. m) Entire Agreement This MSA, the SLAs & all schedules appended thereto & the contents & specifications of the volumes 1, II, III & IV of the RFP subsequent corrigenda issued thereon & clarification (undertakings) accepted by the GOM constitute the entire agreement between the parties with respect to their subject matter. 7. From the schedule forming part of the contract it is clear that the entire project cost, as per the contract is at ₹ 224,31,50, 106/- The goods used in the project that is capital cost of the project is at Rs.,90,35,70,545/-; and the balance operation cost for 5 years of the entire project which is a 133,95,79,561/ 8
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of Maharashtra. 11. The Applicant submits that prior to the GST regime service tax was an exempted on the contract. 12. It is submitted that as per the agreement the government of Maharashtra released 20% amount of the entire project cost as per the agreement after project Go Live on or about 27 October 2015. The balance amount that is 80% of the total contract value is being released in 20 quarterly equal installments for the further period of 5 years from 27 October 2015 onwards. The quarter is comprised of 3 months viz. April to June, July to September. October to December and January to March of each financial years. 13. The applicant has paid necessary fee for this application of ₹ 5000/- (Five Thousand only). 14. The Copy of the contract along with the Schedules forming part of the contract are annexed herewith for ready reference. 15. According to us the contract in question is a composite supply of works contract as defined in the clause 119 of section 2 of the CGST Act
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aintenance of CCTV based surveillance system for Pune and Pimpri -Chinchwad area. The total fees paid to the applicants as per the agreement for the execution of this contract are at ₹ 2,243,150,105.50/- which includes all the cost components as per scheduled A to S , for a period of 5 years and 10 months of the execution. The Government of Maharashtra released 20% amount of entire project cost. As per agreement after project GO LIVE on or about 27 October 2015. The balance amount i.e. 80% of the total contract value is being, released in 20 quarterly equal installments for the further period of five years from 27 October, 2015 onwards. The Government of Maharashtra has issued letter to the Applicant for Final; Acceptance Certificate for Design, Development, Implementation & Maintenance of CCTV based Surveillance System for Pune & Pimpri-Chinchwad and declared the project GO LIVE from The issuance date of letter on 27 October 2015. The Applicant has submitted invoices dt.
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aharashtra (Home Department) as per the contract in question are taxable under SGST/CGST Act ? Comments:- This activity of the Applicant is Works contract as defined in section 2(119) of CGST Act is a composite supply and shall be treated as 'supply of service 'para 6(a) of Schedule II of CGST Act and which attracts tax under SGST CGST Act. Question 2 :- If answer to the question No.1 is an affirmative then what is the rate of tax under SGST/CGST ? Comments:- As per sr.no. 3(xii) of Notification No.11/2017-Central Tax (Rate) (updated version of the Notification No.11/2017-Central Tax(Rate) dated the 28th June, 2017 as amended upto 27th July, 2018) New Delhi, the 28th June,2017 the tax rate is SGST- 9% & CGST- 9%) 04. HEARING The Preliminary hearing in the matter was held on 05.12.2018, Sh. Prakash Shah, Director, Sh. Vijay Walunj, Authorized signatory,Sh. Pradeep Rawal, Manager Accounts Finance, along with Sh. V. V. Guthe, Advocate appeared and made oral and written submiss
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fer this contract as Surveillance Project . The issues before us are: Question 1: whether there is liability to pay tax under the GST law on the amount received post GST for supply of services as per the contract executed prior to the implementation of GST and Question 2: if the said amount is held to be taxable, then at what rate tax should be paid. Both the questions are inter-connected. Answers to both the questions depend on the determination of the nature of the activity being carried out by the applicant and once the nature of the activity is determined the question both the questions as to whether the activity is covered under the GST law or not, and the applicable rate of duty can be determined. To determine the nature of activity of the applicant it is required to be determined whether the contract involves composite supply as defined under the SGST/CGST Act and further whether such supplies constitute a Works Contract as defined in clause (119) of section 2 of the GST Act. We
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sign, development, implementation and maintenance of CCTV based surveillance system and are integrated in such way that all of them constitute, on the over all, a supply to set up a comprehensive CCTV based city surveillance system. In this view of the matter we are convinced that various supplies as contemplated by the contract constitute composite supply as defined u/s 2(30) which reads as follow- Section 2(30): Composite supply means a supply made by a taxable person to a recipient consisting of two or more taxable supplies of goods or services or both, or any combination thereof, which are naturally bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply; Illustration: Where goods are packed and transported with insurance, the supply of goods, packing materials, transport and insurance is a composite supply and supply of goods is a principal supply As a corollary of above finding, the next issue to be decided by us
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with the supply of goods but it extends till the successful testing, commissioning and also to maintenance of the system. The present contract in our view is a works contract as it involves provision of services and goods, but it is for us to decide whether it is works contract as defined under the GST Act cited supra. The term 'immovable property' has not been defined under the GST Act. However, there are plethora of judgments of the Hon. Supreme Court and the Hon. High Courts which have helped understand the term 'immovable property'. One such decision is TTG Industries Ltd. vs. CCE reported as (2004) 4 SCC 751 = 2004 (5) TMI 77 – SUPREME COURT OF INDIA. We can now look at how the judgment has been delivered – 8. In their reply to the show-cause, the respondents explained the processes involved, the manner in which the equipments were assembled and erected as also their specifications in terms of volume and weight. It was explained that the function of the drilling ma
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rilling machine as well as the mudgun are erected on a concrete platform described as the cast house floor which is in the nature of a concrete platform around the furnace. The cast house floor is at a height of 25 feet above the ground level. On this platform concrete foundation intended for housing drilling machine and mudgun are erected. The concrete foundation itself is 5-feet high and it is grouted to earth by concrete foundation. The first step is to secure the base plate on the said concrete platform by means of foundation bolts. The base plate is 80 mm mild sheet of about 5 feet diameter. It is welded to the columns which are similar to huge pillars. This fabrication activity takes place in the cast house floor at 25 feet above ground level. After welding the columns, the base plate has to be secured to the concrete platform. This is achieved by getting up a trolley way with high beams in an inclined posture so that base plate could be moved to the concrete platform and secured
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d condition. 10. The judicial member noticing these facts observed that it is a physical and engineering impossibility to assemble mudguns or the tap hole-drilling machines elsewhere in a fully assembled condition and thereafter erect or install the same at a height of 25 feet on the cast floor of the blast furnace. She found that even the adjudicating authority conceded the fact that the equipments have to be assembled/erected on the base frame projection of the furnace. She also accepted the submission urged on behalf of the appellant that if the machines are to be removed from the blast furnace, they have to be first dismantled into parts and brought down to the ground only by using cranes and trolley ways considering the size, and also considering the fact that there is no space available for moving the machines in assembled condition due to their volume and weight. She found support for her conclusion in the decision of this Court in Municipal Corpn. of Greater Bombay v. Indian Oi
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the ratio of the above case-law, we hold that the mudguns and tap hole-drilling machines do not admit of the definition of goods and, therefore, excise duty is not leviable thereon. 25. In Mittal Engg. Works (P) Ltd. v. CCE [(1997) 1 SCC 203 : (1996) 88 ELT 622] =1996 (11) TMI 66 – SUPREME COURT OF INDIA this Court was concerned with the exigibility to duty of mono vertical crystallisers which are used in sugar factories to exhaust molasses of sugar. The material on record described the functions and manufacturing process. A mono vertical crystalliser is fixed on a solid RCC slab having a load-bearing capacity of about 30 tons per square metre. It is assembled at site in different sections and consists of bottom plates, tanks, coils, drive frames, supports, plates, etc. The aforesaid parts were cleared from the premises of the appellants and the mono vertical crystalliser was assembled and erected at site. The process involved welding and gas-cutting. After considering the material pla
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Heading 85.02. In reaching this conclusion this Court considered the earlier judgments of this Court in Municipal Corpn. of Greater Bombay v. Indian Oil Corpn. Ltd. [1991 Supp (2) SCC 18] = 1990 (11) TMI 407 – SUPREME COURT, Quality Steel Tubes [(1995) 2 SCC 372 : (1995) 75 ELT 17] = 1994 (12) TMI 75 – SUPREME COURT OF INDIA and Mittal Engg. Works (P) Ltd. [(1997) 1 SCC 203: (1996) 88 ELT 622] = 1996 (11) TMI 66 – SUPREME COURT OF INDIA as also the earlier judgment of this Court in Sirpur Paper Mills Ltd. v. CCE [(1998) 1 SCC 400: (1998) 97 ELT 3] = 1997 (12) TMI 109 – SUPREME COURT OF INDIA. This Court observed: (SCC pp. 35-36, para 14) 14. There can be no doubt that if an article is an immovable property, it cannot be termed as 'excisable goods' for purposes of the Act. From a combined reading of the definition of 'immovable property' in Section 3 of the Transfer of Property Act, Section 3(26) of the General Clauses Act, it is evident that in an immovable property th
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tion in the instant case. The machines in question were by their very nature intended to be fixed permanently to the structures which were embedded in the earth. The structures were also custom-made for the fixing of such machines without which the same could not become functional. The machines thus becoming a part and parcel of the structures in which they were fitted were no longer movable goods. It was in those peculiar circumstances that the installation and erection of machines at the sites were held to be by this Court to be immovable property that ceased to remain movable or marketable as they were at the time of their purchase. Once such a machine is fixed, embedded or assimilated in a permanent structure, the movable character of the machine becomes extinct. As can be understood from the above judgements, the Honourable Courts have evolved the term 'immovable property' when faced with the question of what constitutes movable and lmmovable property. Though not issued fo
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following reasons:- 1) CCTV based Surveillance System have permanently been fastened to the things attached to the earth. 2) The CCTV based Surveillance System cannot not be shifted without first dismantling it and then erecting it at another site. In the facts before us and having regard to the principles laid down in the judgments discussed above, we are of the firm view that set up of a comprehensive CCTV based city surveillance system for the city of Pune and Pimpri-Chinchwad does result into installation/commissioning of immovable property wherein transfer of property in goods is involved in the execution of the contract and thus the 'Surveillance Project' is a works contract as defined in Sub-section 119 of Section 2 of the GST Act and is supply of services as per 6(a) of Schedule II of the GST Act. And therefore the amount received for the supply of services post GST are taxable under the provision of GST Act. Question No. 2: Having answered the question No.1 in the aff
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nd is reproduced as under:- SI. No. Chapter, Section or Heading. Description of Service Rate (per cent.) Condition 1 2 3 4 5 Chapter 99 All Services Section 5 Construction Services Heading 9954 (Construction services) (i) ………………………………) 9 – (ii) composite supply of works contract as defined in clause 119 of section 2 of Central Goods and Services Tax Act, 2017.' 9 – (iii) Composite supply of works contract as defined in clause (119) of section 2 of the Central Goods and Services Tax Act,2017, supplied to the Government, ………….. alteration of, (a) a historical monument, archaeological site or remains of national importance, archaeological excavation, or antiquity specified under the Ancient Monuments and Archaeological Sites and Remains Act, 1958 (24 of 1958);(b) canal, dam or other irrigation works; (c) pipeline, conduit or plant for (i) water supply(ii) water treatment, or (iii) sewerage treatment or disposal. 6 – (iv) Composite supply of works contra
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said Notification with the amendment mentioned above also it is very clear that the composite supply of works contract as in the subject case falls under (ii) attracting 18% GST. The said Notification 11/2017 was further amended on 21.09.2017 vide Notification No. 24/2017 – Cen Tax (Rate) and is reproduced as under:- SI.No. Chapter, Section or Heading. Description of Service Rate (per cent.) Condition 1 2 3 4 5 Chapter 99 All Services Section 5 Construction Services Heading 9954 (Construction services) (i) ………………………………) 9 – (ii) composite supply of works contract as defined in clause 119 of section 2 of Central Goods and Services Tax Act, 2017.' 9 – (iii) Composite supply of works contract …………………. 6 – (iv) Composite supply of works contract ………………. 6 – (v) Composite supply of works contract as 6 defined in clause. (119) of section 2 of the Central Goods and Services Tax Act, 2017, supplied by way of construction, erection, commissi
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ated 13.10.2017, the original Notification No. 11/2017 stood as under:- SI.No. Chapter, Section or Heading. Description of Service Rate (per cent.) Condition 1 2 3 4 5 Chapter 99 All Services Section 5 Construction Services Heading 9954 (Construction services) (i) ………………………………) 9 – (ii) composite supply of works contract as defined in clause 119 of section 2 of Central Goods and Services Tax Act, 2017.' 9 – (iii) Composite supply of works contract …………………. 6 Provided that where the services are supplied to a Government Entity, they should have been procured by the said entity in relation to a work entrusted to it by the Central Government, State Government, Union territory or local authority as the case may be (iv) Composite supply of works contract ………………. 6 – (v) Composite supply of works contract as 6 defined in clause. (119) of section 2 of the Central Goods and Services Tax Act, 2017, supplied by way of construction, erection,
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lation to a work entrusted to it by the Central Government, State Government, Union territory or local authority as the case may be Notification 31/2017 Dt.13.10.2017 (vii) Composite supply of works contract as defined in clause (119) of section 2 of the Central Goods and Services Tax Act, 2017, involving predominantly earth work (that is, constituting more than 75per cent, of the value of the works contract) provided to the Central Government, State Government, Union territory, local authority, a Governmental Authority or a Government Entity. 2.5 Provided that where the services are supplied to a Government Entity, they should have been procured by the said entity in relation to a work entrusted to it by the Central Government, State Government, Union territory or local authority as the case may be Notification 31/2017 Dt.13.10.2017 (viii) Composite supply of works contract as defined in clause (119) of section 2 of the Central Goods and Services Tax Act, 2017 and associated services,
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r providing services specified in item (iii) or item (vi) above to the Central Government, State Government, Union territory, a local authority, a Governmental Authority or a Government Entity 6 Provided that where the services are supplied to a Government Entity, they should have been procured by the said entity in relation to a work entrusted to it by the Central Government, State Government, Union territory or local authority, as the case may be. (x) Composite supply of works contract as defined in clause (119) of section 2 of the Central Goods and Services Tax Act, 2017 provided by a subcontractor to the main contractor providing services specified in item (vii) above to the Central Government, State Government, Union territory, a local authority, a Governmental Authority or a Government Entity. 2.5 Provided that where the services are supplied to a Government Entity, they should have been procured by the said entity in relation to a work entrusted to it by the Central Government,
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k is of the type of original work. The expression 'Original work' has not been defined under any of the Notifications applicable to the present case. The expression 'original work' has assigned meaning under the CPWD Works Manual 2014 which reproduced as below: 1.3.1 Original Works These shall mean:- (i) all new constructions, (ii) all types of additions, alterations and/or special repairs to newly acquired assets, abandoned or damaged assets that are required to make them workable. (iii) major replacements or remodeling of a portion of an existing structure or installation or other works, which results in a genuine increase in the life and value of the property. Thus' Original Works' would mean ; all new constructions; all types of additions and alterations to abandoned or damaged structures on land that are required to make them workable; erection, installation etc. that results in increase in life and value of property . In the present case the work done by t
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