As per the case facts the core issue in these appeals was whether specific educational institutions fell under the definition of governmental authority in a Service Tax Exemption Notification which ... would exempt construction services provided to them from service tax The reason for the appeal to the Supreme Court was to obtain a definitive interpretation of the governmental authority definition within the exemption notification and its application to these institutions The question arose whether the Indian Institute of Technology Patna and the National Institute of Technology Rourkela are covered by the definition of governmental authority under the Mega Service Tax Exemption Notification thereby making construction services rendered to them exempt from service tax Finally the Supreme Court dismissed the appeals and upheld the impugned judgments implying that the institutions were not considered governmental authorities for this exemption The Court emphasized that statutory interpretation should make a law workable not lead to judicial overreach simply because a statute doesn't achieve desired results