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12. The period involved in this appeal is from 01.04.2013 to 31.03.2014. Thus, clause (s) as it stood when the Exemption Notification was issued on 20.06.2012, and as it stood when it was amended on 30.01.2014 would be relevant.

13. Learned counsel for the appellant has placed reliance upon the decision of the Supreme Court in Shapoorji Pallonji. This decision interpreted the amended clause (s) of the Exemption Notification, which amendment came into effect w.e.f. 30.01.2014. The Supreme Court placed emphasized on the 'semicolon' and 'comma' used in the amended definition and observed that the conjunction 'or' between sub-clauses (i) and (ii) divides the clauses into two parts and, therefore, both the parts would be independent of each other. Thus, a 'governmental authority' would mean either an authority or a board or any other body set up by an Act of the Parliament or a State Legislature or an authority or a board or any other body established by government, with 90% or more participation by way of equity or control by the Government, to carry out any function entrusted to a municipality under article 243W of the Constitution.