Held: It is adequately evident that the activities, which merit classification under SAC 998621, are in the nature of physical performance or activities which are being directly used in the mining and extraction operations whereas the services provided by the Appellant are not so as the said services are in the nature of review, monitoring, management and supervision of the project works which are done towards real.....

Held: We find that, the applicant has been appointed as a Project Management Consultant to manage the Project right from the detail design to commissioning and is required to review, monitor, manage and control all aspects of the execution of the Project. In other words, the applicant has to review, monitor, manage and control all aspects of the execution of the Project undertaken by the EPC Contract.....