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Custom, Excise & Service Tax Tribunal

Bansal Brothers Through Shri Vijay ... vs Cgst & Ce Agra on 16 October, 2025

CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL
                  ALLAHABAD

                REGIONAL BENCH - COURT No.II

             Service Tax Appeal No.70739 of 2018

(Arising out of Order-in-Appeal No.182/ST/Appeal/Audit/LKO/2018 dated
27/03/2018 passed by Commissioner (Audit) Central Goods & Services Tax,
Lucknow)

M/s Bansal Brothers,
Through Shri Vijay Kumar Bansal, Proprietor.....Appellant
(11-C, Govind Nagar, Mathura-281003)
                                VERSUS

Commissioner of Central Excise &
Service Tax, Agra                                        ....Respondent
(7-Havelock Road, Lucknow)

APPEARANCE:
Ms Vanashri Dubey, Advocate for the Appellant
Shri Santosh Kumar, Authorised Representative for the Respondent



CORAM:       HON'BLE MR. SANJIV SRIVASTAVA, MEMBER (TECHNICAL)
             HON'BLE MR. ANGAD PRASAD, MEMBER (JUDICIAL)


                 FINAL ORDER NO.70742/2025


              DATE OF HEARING                :              18 July, 2025
      DATE OF PRONOUNCEMENT              :               16 October, 2025


SANJIV SRIVASTAVA:


      This    appeals   directed    against      Order-In-Appeal     No.:
182/ST/Appeal/     Audit/    LKO/    2018        dated    27.03.2018   of
Commissioner (Audit) Central Goods & Services Tax And Central
Excise Lucknow, to whom Central Board of Excise and Customs
in exercise of powers conferred under Rule 3 of Central Excise
Rules 2002, Rule 3 of the Service Tax Rules 1994 and Section
174(2)(e) of Central Goods & Services Tax Act 2017, read with
Notification No. 26/2017 (CE-NT) dated 17.10.2017 vide order
No. 09/2017 dated 16.11.2017 issued vide F. No. 137/13/2017-
                                                          Service Tax Appeal No.70739 of 2018
                                          2


Service tax has assigned the appeal cases. By the impugned
order      appeal       filed     against     the       Order-in-Original             No.
34/Adj/ST/2017 dated 28.02.2017 of Deputy Commissioner,
Central Excise         &      Service   Tax, Division Aligarh              has      been
dismissed

2.1     Appellant       is     having    Service        Tax    Registration           No.
ABNPB5282DSD001 w.e.f. 08.08.2012 and engaged in providing
the services of Work Contract Services' which is taxable under
Section 65(105)(zzzza) of the Finance Act, 1994 (hereinafter
referred to as 'the Act') upto 30.06.2012 and thereafter w.e.f.
01.07.2012 falling under the definition of Service tax as being
defined under Section 65B(44) of the Act and clause (h) of
Section 66E, thus service tax is liable to be collected by the
Central Government as per the provisions of Section 66B and
66BA of the Act.

2.2     The appellant was engaged in providing services to
Mathura Vrindavan Development Authority (MVDA), Senior Asstt.
Financial Advisor (Construction) NCR, L&T Ltd. (under sub-
contract for Jal Sansthan), Indian Oil Corporation Ltd, and Shri
Brij Housing and Developers (Brij Housing.

2.3     Acting on the information/ intelligence that appellant was
not discharging the service due properly, investigations and
enquiries were initiated against the appellant .

2.4     During the course of investigation the records were called
for from the appellant and his statement was also recorded

2.5     On the basis of the documents and statement of the
appellants it was found that

    appellant has short paid service tax as calculated in the
        table below on the service provided to M/s Indian Oil
        Corporation Limited (IOCL) of "Horticulture jobs in GR
        Township including Administrative Building & Green belt",
        "Repair and Maintenance of Civil Works", "Repair of
        Bachelor Hostel" etc;
        Financial   Service       Receipt     Taxable     Service            Tax    Service Tax
        Year                      as per 26   Value       Payable
                                                       Service Tax Appeal No.70739 of 2018
                                       3

                             AS                        Total        By           Paid       Short
                                                                    Service                 Paid
                                                                    Provider
   2010-11     Work          16224590      15582587    642003       642003       0          642003
               Contracts     5216371       5009961     206410       206410       0          206410
   2011-12
   2012-13                   2421111       2307050     114061       114061       131568     256850
   (Apr-
   Jun)
   2012-13                   7761448       7395800     365648       182824
   (Jul-
   Mar)
   2012-13     Repair    &   2298962       2115893     183067       91534
   (Jul-       Maintenance
   Mar)
   2013-14                   21794825      20059295    1735530      867765       946176     0

   2014-15                   17439233      16050540    1388693      694346       577168     117178

   Total                                                                                    1222441

 appellant had not paid service tax on the services provided
   to Mathura Vrindavan Development Authority (MVDA),
   Mathura, M/s L & T and Shri Brij Housing & Developers, as
   detailed in table below:
   Financial   Receipt as per 26AS     Taxable       Rate of    Service Tax Payable
   Year        u/s 194C                Value         Service
               Name      Amount                      Tax        Recipient      Provider

   2010-11     MVDA        32441427    31157729      4.12%      0              1283698
               L&T         5351812     5140042       4.12%      0              211770
   2011-12     MVDA        43018097    41315883      4.12%      0              1702214
               L&T         1637438     1572645       4.12%      0              64793
   2012-13     MVDA        4303702     4100951       4.94%      0              202751
   (Apr-
   Jun)
   2012-13     MVDA        2373829     2261996       12.36%     55917          55917
   (Jul-       Brij        1850000     1762845       12.36%     43578          43578
   Mar)        Housing

   2013-14     MVDA        884696      843017        12.36%     20839          20839
   Total                                                                       3585560

 the appellant had calculated his service tax liabilities under
   the Composition Scheme of Works Contract and paid the
   same from the date of taking registration of Service Tax
   and also admitted that the services provided before the
   registration also falls under the category of 'Works
   Contract' and thus liable to Service Tax.
 during the financial year 2010-11 to 2014-15 the appellant
   provided the taxable service of Work Contract Services and
   have received payments in lieu of the services provided by
                                                         Service Tax Appeal No.70739 of 2018
                                        4


         them but they failed to pay the service tax to the
         department.
   during the investigation and after pursuance of the
         Department, the party deposited Service Tax amount of
         Rs.3,92,150/- vide Challan. No.4 dated 21.09.2015 against
         their admitted liability.

2.6      A Show cause notice dated 21.10.2015 was issued to the
appellant to show cause as to why:-

  (i)          Service   Tax    total       amounting       to    Rs.48,08,001/-
               (including Cess & S.H.E.Cess) [Rupees Forty Eight
               Lakhs Eight Thousand and One only) short paid/not
               paid for the period 2010-11 to 2014-15 should not
               be demanded and recovered from them under
               proviso to Section 73(1) of the Finance Act,1994 and
               as to why the amount of Rs.3,92,150/- deposited by
               the noticee against heir admitted Service Tax liability
               should not be appropriated against the Service Tax
               demand made herein.
  (ii)         Interest at the appropriate rate for the relevant
               period till the payment of the Service Tax should not
               be demanded and recovered from them under the
               provisions of Section 75
  (iii)        Late Fees for late filing of the ST-3 returns as per
               provisions of Section 70 of the Act read with Rule 7C
               of the Service Tax Rules, 1994 should not be
               imposed upon them.
  (iv)         Penalties should not be imposed upon them under
               Section    77(1)(a),         77(1)(b),     77(1)(c)         discussed
               supra. and 77(2) of the Act ibid for contravention of
               various provisions of the Act and the Rules made
               there under as discussed supra.
  (v)          Penalty should not be imposed upon them under
               Section 78 of the Act ibid for the reasons discussed
               above.
                                              Service Tax Appeal No.70739 of 2018
                                 5


2.7     The show cause notice was adjudicated as per the order in
original referred in para 1 above, holding as follows:

   a.     I confirm the demand of Service Tax including all cesses
          amounting to Rs.44,87,860.00 (Rupees Forty Four Lakh
          Eighty Seven Thousand Eight Hundred Sixty only) and
          order for its recovery from M/s. Bansal Brothers, Prop.
          Shri Vijay Kumar Bansai, House No. 11-C, Govind
          Nagar, Mathura under proviso to Section 73(1) of the
          Finance Act, 1994. I also order to appropriate the
          Service Tax amounting to Rs.3,92,150/-(Rupees Three
          Lakh Ninety two Thousand One Hundred Fifty only)
          deposited by the party against the above said confirmed
          demand;
   b.     I drop the demand of Rs.3,20,141/-(Rupees Three
          Lakhs Twenty Thousand and one hundred forty one
          only) as discussed in the forgoing Para's.
   c.     I confirm the demand of interest at the appropriate rate
          for the relevant period till the payment of Service Tax
          as confirmed here-in-above and order for its recovery
          from M/ s. Bansal Brothers, House No.11-C, Govind
          Nagar, Mathura, under Section 75 of the Finance Act,
          1994;
   d.     I impose a penalty of Rs.44,87,860 /- (Rupees Forty
          Four Lakh Eighty Seven Thousand Eight Hundred Sixty
          only) upon M/s. Bansal Brothers, House No. 11-C,
          Govind Nagar, Mathura, under Section 78 of the Finance
          Act, 1994 as discussed in the forgcing Para's;
   e.     I also impose/demand Late Fee for amounting to
          Rs.1,00,000/- upon M/s. Bansal Brothers, House No.
          11-C, Govind Nagar, Mathura, for non filling of five ST-3
          returns as per provisions of Section 70 of the Act read
          with Rule 7C of the Rules, as discussed in the forgoing
          Para's;
   f.     I also impose a penalty of Rs.10,000/- (Rupees Ten
          Thousand only) upon M/s. Bansal Brothers, House No.
          11-C, Govind Nagar, Mathura, under Section 77(2) of
                                               Service Tax Appeal No.70739 of 2018
                                 6


         the Finance Act, 1994. And drop the penalties under
         Section 77(1)(a), 77(1)(b), 77(1)(c), of the Finance
         Act, 1994-as discussed in the forgoing paras;

2.8   Aggrieved     appellant   filed   the   appeal         before        the
Commissioner (Appeal) which has been dismissed as per the
impugned order.

2.9   Aggrieved appellant has filed this appeal.

3.1   We have heard Ms Vanashri Dubey, Advocate for the
appellant and Shri Santosh Kumar, Authorized Representative
for the revenue.

3.2   Arguing for the appellant counsel submits:

   the services provided to M/s IOCL (Horticulture and supply
      of sand) and MVDA are taxable services is based on wrong
      factual
   the supplies of sand to IOCL vide W.O. No. 23741408 and
      W.O. No. 17814589 are not liable to service tax.
   Appellant provided the Horticulture services to M/s IOCL at
      locations other than the factory premises i.e. GR Township,
      these are not liable to service tax.
   construction of residential houses for Poor Persons under
      IHSDP are constructed under JNNURM scheme therefore,
      in view of exemption notification No. 28/2010-ST dated
      22.06.2010 and further notification No. 25/2012-ST dated
      20.06.2012 SI.No. 13 are exempted from service tax.
   the services provided to MVDA in relation to the housing
      projects under Shri Kanshiram Ji Sahkari Gareeb Awas
      Yojana is squarely under S.No. 12 of the Notification No.
      25/2012 S.T as much as MVDA is a governmental authority
      and the construction done for it is specifically exempt
      under the said exemption notification.
   the housing projects of MVDA are constructed with a not-
      for-profit motive and hence would be classified as original
      work      meant   predominantly   for   the    use      other      than
      commerce, industry or any other business or profession.
                                            Service Tax Appeal No.70739 of 2018
                                     7


   the issue is squarely covered by the judgement of Hon`ble
      Punjab and Haryana High Court in M/s Bharat Bhushan
      Gupta and Company y/s State of Haryana and others.
   allegation of deliberately and knowingly suppression of
      material facts from the department with a malafide
      intention to evade payment of service tax is purely
      unrealistic and illusionary.
   The appellant is regular in filing of service tax returns and
      depositing service tax thereby making due compliances.
      The appellant being a law abiding citizen have fulfilled all
      possible tax compliances, there cannot be any suppression
      with intent to evade the tax as has been alleged in the
      impugned order-in-original.
   action of levying interest under Section 75 and penalty
      under Section 70, 77(2) and Section 78 of the Act is not
      admissible and valid.
   penalties under the Act is not automatic and there should
      be mens rea or guilty state of mind for imposition of
      penalties.
   adjudicating authority failed to appreciate the fact that the
      appellant had not suppressed any information from the
      department with the intention to evade payment of service
      tax and has neither defaulted in payment of service tax.
   appellant had always supported in the enquiry proceedings
      initiated by the department and had submitted all the
      relevant documents with the department from time to
      time.
   on becoming aware of the service tax liability, appellant
      deposited Rs. 3,92,150/-.
   There is no malafide intention on the part of the appellant
      and hence, extended period of limitation cannot be
      invoked.

3.3   Authorized Representative reiterated the findings recorded
in the impugned order.
                                               Service Tax Appeal No.70739 of 2018
                                  8


4.1   We have considered the impugned order along with the
submissions made in appeal and during the course of arguments.

4.2   Impugned order records the findings as follows:

      "I have gone through the order-in-original, grounds of
      appeal, submissions of the appellant at the time of
      personai hearing and facts on record. I find that the crucial
      issue involved in the case is whether appellant was liable
      to pay Service Tax on the gross amount received in lieu of
      providing services of Work Contract Services and Repair
      and Maintenance Services as alleged in the Show Cause
      Notice.

      The issues - wise discussion are as under:

      1. Services provided to M/s India Oil Corporation
         (IOCL):-

      On this issues the appellant as submitted that the services
      provided to M/s IOCL in respect of Horticulture job are
      liable to service tax. The adjudicating authority has
      discussed the issue in para 40 of the order in original and
      as per facts of the case the work order is for the work of
      horticulture job in GR Township including administrative
      buildings and green belt that as per documents the work
      was awarded by M/s IOCL refinery for the purpose of
      maintenance of garden/ tree plantation and to develop the
      adequate green belt inside the premises to control noise
      pollution created by the refinery. The nature of the service
      rendered by the appellants are in respect of commercial
      activity on this issue i agree with the observation made by
      the adjudicating authority that the exemption the benefit
      of the exemption from service tax cannot be extended to
      the   appellants.   The   observation   of     the     adjudicating
      authority finds force from the case laws quoted by the
      adjudicating authority wherein the Hon`ble Tribunal has
      allowed the CENVAT Credit of Service Tax paid by the
      parties on these services the reasonable inference from
      these case laws cited by the adjudicating authority can be
                                        Service Tax Appeal No.70739 of 2018
                           9


drawn that the service was found to be taxable and service
was paid by the parties and they had approached tribunal
for the purpose of availment of cenvat credit paid by them
on these services therefore, I hold that the order passed
by the adjudicating authority confirming the demand of
service tax needs no interference.

In their defence the appellant has submitted that they
have supplied sand vide Work Order No. 23741408.
However, the supply of sand was for cable trenches
therefore, it is a part of the work contract service and it
can be treated as a separate contract for supply of the
material. Further, it is a part of composite contract and
cannot be treated separately. Therefore, the plea of the
appellant is mis-leading cannot be accepted.

2. Services    provided    to   M/s    Mathura         Vrindavan
   Development Authority :-

On this issue the appellant submitted that the services
provided to M/s Mathura Vrindavan Development Authority
are exempt by virtue of Sl.No. 14(c) of the Notification No.
25/2012-ST dated 20.06.2012 and quoted the provisions
of said notification.

The issue has been discussed by the adjudicating authority
in para 41, 41.1 and 41.2 of the order in original wherein
the adjudicating authority has discussed that service
provided to MVDA by the appellant are taxable or not. The
Adjudicating authority has observed that the appellant has
not furnished_ any evidence to prove that the said project
is approved by the competent authority under the said
scheme.     Therefore,   the    adjudicating     authority          has
disallowed the exemption claimed by the appellant. In the
grounds of appeal they have submitted that the services
have been provided to the Government and they are
entitling for exemption under SI.No. 12A of exemption
Notification No. 25/2012-ST dated 20.06.2012. Here also
that the appellant have failed to give any documentary
                                                  Service Tax Appeal No.70739 of 2018
                                     10


evidence to prove that the said project was approved by
the competent authority empowered under the scheme of
affordable housing in partnership framed by the Ministry of
Housing and Urban Poverty Alleviation, Government of
India.       The        appellant    has   claimed    exemption           under
Notification No. 25/2012-ST dated 20.06.2012 SI.No. 13 of
the said exemption read as under :-

"13. Services provided by way of construction, erection,
commissioning, installation, completion, fitting out repair,
maintenance, renovation, or alteration of, -

(a)      ....
(b)      a      civil    structure    or   any   other     original       works
         pertaining to a scheme under Jawaharlal Nehru
         National Urban Renewal Mission or Rajiv Awas
         Yojana"

The appellant have failed to given any documentary
evidence that the said project was for Rajiv Awas Yojana.
Therefore, in absence of non fulfillment of conditions the
exemption can not extended to the appellant. Moreover,
the appellant himself is not sure about the claim of the
exemption Notification the appellant are changing their
stand in respect of claim of exemption because at one
point of time they have claimed exemption under SI.No.
12 of the Notification and also 14 of the Notification before
the original adjudicating authority and now in their
additional defence submission under SI.No. 13 of the said
Notification. Therefore, the exemption benefit in absence
of documentary evidence that the scheme was under
JNNURM can not be extended.

In the case of Commissioner of C.Ex. & Cus, Indore v/s
Parenteral Drugs (I) Ltd. - 2009(236)ELT.625(S.C.) -
Hon'ble Supreme Court has held in para 8 of the
judgement               that   -    "Exemption    notifications         to      be
interpreted strictly - Burden on assessee to prove that the
                                            Service Tax Appeal No.70739 of 2018
                               11


      item falls within four corners of exemption notification -
      Section 5A of Central Excise Act, 1944."

      As regards imposition of the penalty under Section 78 of
      the Act, I agree with the findings adjudicating authority
      that the party have deliberately suppress the gross receipt
      against the provisions of taxable services and have not
      obtained services tax registration within stipulated time
      they have also not of paid service tax during the impugned
      period that it was a willful attempt to evade payment of
      service tax. Therefore, they are liable for penal action
      under Section 78 of the Act. That Hon'ble Supreme Court
      has settled the issue in the case of UOI of v/s Dharmendra
      Textiles Processors [2008(231)ELT 3(S.C.)], wherein it was
      pronounced that the present of malafide intention is not
      relevant for imposing penalty and mensrea is not an
      essential ingredient for penalty for tax delinquency which
      is a civil obligation. Hence, I upheld the penalty imposed
      by adjudicating authority under Section 78 of the Act.

      As regards penalty imposed by the adjudicating authority
      under Section 72(2) of the Act Rs. 10,000/- and late fees
      of Rs. 1,00,000/- under Section 70 read with Rule 7C of
      the Act I agreed with the findings of the adjudicating
      authority and penalty imposed are upheld."

4.3   Undisputedly demand made in respect of the services
provided by the Appellant to M/s L & T, Brij Housing have been
dropped by the adjudicating authority. The demand has been
confirmed only in respect of the services provided to MVDA and
M/s IOCL.

4.4   During the investigation certain work orders in respect of
the service provided by the appellant to M/s IOCL were provided.
Summary of these work orders, to determine the service being
provided by the appellant in terms of these work orders is
available in para 8 of SCN and is reproduced below:

  (a) W.O No 17814589 dated 15.09.2008 of M/s. IOCL,
       Gujarat Refinery: the nature of work to be executed is
                                              Service Tax Appeal No.70739 of 2018
                                12


      termed as Horticulture jobs in GR Township including
      Administrative    Buildings & Greenbelt; Scheduled time
      period for completion of the work is 01 year and the value
      of work includes all taxes and charges, except Service
      Tax. The Service Tax as applicable shall be paid by IOCL
      as per tender
(b) W.O. No.23472655 dated 17.10.2011 of M/s. IOCL,
      Mathura Refinery, Mathura: the nature of work to be
      executed    is   termed   as     Construction       of     Emblem/
      Monogram structure in the main lawn of MJPL, Mathura;
      Scheduled time period for completion of the work is till
      30.11.11and the value of work includes all taxes and
      charges
(c) W.O. No.23479701 dated 25.10.2011 of M/s. IOCL,
      Mathura Refinery: the nature of work to be executed is
      termed as Repair & Maintenance of Civil Works in ETP,
      SRU, MSQ, Eco-Park, Bitumen Tank Farm and LPG area in
      SR-8   at   Mathura   Refinery;     Scheduled          period        for
      cơmpletion of work is notified as 23 months; the value of
      work is including Service Tax.
(d) W.O. No.23482838 dated 02.11.2011 of M/s. 1OCL,
      Mathura Refinery: the nature of work to be executed is
      termed as Repair & Maintenance of Civil Works in New
      Unit, Hydrogen Bullet, Central Stores, Water Block and
      Flare area at Mathura Refinery; Scheduled period for
      completion of work is notified as 23 months; the value of
      work is including Service Tax
(e) W.O. No.23619631 dated 12.05.2012 of M/s. IOCL,
      Mathura Refinery: the nature of work to be executed is
      termed as Repair & Maintenance of Civil Works of
      Residential Quarters and various public buildings of
      Mathura Refinery Nagar Part-B; Scheduled period for
      completion of work is notified as 24 months; the value of
      work is including Service Tax.
(f)   W.O. No.23672094 dated 30.07.2012 of M/s. IOCL,
      Mathura Refinery: to be executed is termed as Repair &
                                              Service Tax Appeal No.70739 of 2018
                                 13


         Maintenance of Civil farm area at Mathura Refinery;
         Scheduled period for completion of work is notified as 23
         months; the value of work is including Service Tax.
  (g) W.O. No.23741408 dated 09.11.2012 of M/s. IOCL,
         Mathura Refinery: the nature of work to be executed is
         termed as Supply of Sand for the cable trenches of Old
         Units in SRB at Mathura Refinery; Scheduled period for
         completion of work is notified as 02 months;
  (h) W.O. No.23789443 dated 24.01.2013 of M/s. IOCL,
         Mathura Refinery: the nature of work to be executed is
         termed as Renovation of two blocks (40 units) of Bachelor
         Hostel (BOH) at Mathura Refinery Nagar; Scheduled
         period for completion of work is notified as 061 months;
         the rate of Service Tax reimbursable @ 7.416%.
  (i)    W.O. No.24255523 dated 23.09.2014 of M/s IOCL,
         Mathura Refinery: the nature of work to be executed is
         termed as Repair & Maintenance of Civil Works in New
         Unit, Hydrogen Bullet, Central Stores, Water Block and
         Flare area at Mathura Refinery Scheduled period for
         completion of work is notified as 06 months; the rate of
         Service Tax reimbursable @7.416%.

4.5     Appellant do not dispute the leviability of service tax in
respect of these work order except for work order in respect of
horticulture services and the work order for supply of sand.

4.6     In respect of the work order in respect of horticulture
services, appellant submits that these services were provided at
location other than the factory premises of the service recipient
and hence cannot be subjected to service tax. We do not find
any merits in the said argument of the appellant. The service tax
if leviable as per the Finance Act, 1994 (as amended from time
to time) is to be paid if not exempted specifically. Appellant has
not produced any exemption notification to show that during the
relevant period these services if provided at locations other than
the factory premises are exempt from payment of service tax.
Order in original referred to following orders wherein it has been
                                                  Service Tax Appeal No.70739 of 2018
                                   14


held that the service tax paid on the horticulture services will be
admissible as CENVAT Credit

    Maruti Suzuki India Ltd [2015 (38) STR 503 (T-Del)]
    Hero Honda Motors Ltd. [2014 (34) STR 54 (T-Del)]
    ABI Showa Tech India Ltd. [2016 (41) STR 912 (T-
        Chennai)

4.7     We   also   note   that   the   demand     in    respect        of    the
Horticulture Services in terms of Work Order No 17814589 dated
15.09.2008, is for the period prior to introduction of Negative
List regime for levy of service tax. At that time the service tax
was leviable only on services defined as taxable services by the
Finance Act, 1994. It is settled law that for the purpose of levy
of service tax prior to the 01.07.2012, it was necessary to
determine the classification of service rendered. We find that
neither show cause notice, nor the order in original or even the
impugned order have even made an attempt to determine the
classification of these services, amongst the services notified as
taxable service by the Finance Act, 1994. In absence of any such
classification we find that the entire proceedings are vague and
like fishing exercise. In case of Ess Gee Real Estate Developers
Pvt. Ltd [2020 (34) G.S.T.L. 486 (Tri. - Del.)] following has been
held:

        "23. The show cause notice is vague as it does not
        specify which particular category of service was leviable to
        tax as it states that "service tax appears to be leviable as
        per the statutory provisions on real estate developed by
        site preparation on consideration basis". The earlier portion
        of paragraph 8 of the show cause notice mentions that the
        developer in the capacity of a real estate agent rendered
        services of site formation for developing the real estate
        which was ultimately sold by the developer on pre-
        determined commission. It is very difficult to really cull out
        from the show cause notice as to which particular category
        of service was intended to be taxed. The show cause
        notice should have clearly indicated whether the service of
                                                Service Tax Appeal No.70739 of 2018
                                  15


      "real estate agent" or "site formation" was leviable to tax,
      for this is the requirement of Section 65A of the Act. This
      confusion is maintained in the impugned order. After
      referring to the provisions of the agreement dated 5th
      September, 2001, the Commissioner in paragraph 22 of
      the order finds that the service rendered by the appellant
      is of "site formation" as defined in Section 65(97a) of the
      Act. In paragraph 23, the Commissioner also finds that the
      service rendered by the appellant is of "real estate agent"
      as defined in Section 65(88) of the Act. It is for this reason
      that in paragraph 24 of the order, the Commissioner
      observed that it was a composite agreement in which the
      developer has provided the two services to the land owner
      the first service is "site formation" and the second is "real
      estate agent". In the last sentence of the paragraph the
      Commissioner observed "I also find that both the services
      are taxable and there is no need to bifurcate the
      consideration service wise." It was obligatory for the
      Adjudicating Authority to have specifically classified the
      service under which service tax was to be levied. The
      impugned [order], therefore, for this reason alone needs
      to be set aside."

4.8   In   terms   of    the   Work    Order   No    23741408            dated
09.11.2012, appellant was supplying sand to M/s IOCL Mathura
Refinery. Service Tax has been demanded on the same.
Impugned order records that this supply is part of certain work
contract order without specifying which work contract order, has
this supply been        effected. Lower authorities         should have
determined exactly as to what work contract order was being
executed by the appellant against which this sand was supplied.
In absence of any such finding, we find that the supply of sand
was nothing but supply of goods and could not have been
subjected to service tax.

4.9   Thus in respect these two Work Orders namely Work Order
No 17814589 dated 15.09.2008 & Work Order No 23741408
                                                 Service Tax Appeal No.70739 of 2018
                                   16


dated 09.11.2012 we do not find any merits in the demand
made.

4.10 Now coming to the demand made in respect of the services
provided to MVDA. We observe that the show cause notice
records as follows:

      "12. The party has also rendered services to M/s Mathura
      Vrindavan Development Authority, Mathura (hereinafter
      referred to as 'MVDA') for construction of 256 Houses
      under Shri Kanshiramji Gareeb Awas Yojna awarded on
      23.10.08,    construction     of   160    Houses         under        Shri
      Kanshiramji Gareeb Awas Yojna awarded on 07.07.2010,
      construction of 96 EWS Houses awarded on 06.10.2009
      and   construction    of   144     EWS   Houses         awarded          on
      19.07.2010

      13.1 A contract has been awarded to notice by the MVDA
      for the construction of houses under the Project namely
      Shri Kanshiramji Gareeb Awas Yojna and Economical
      Weaker Section houses. On going through the Work Order,
      it appears that the contract is a composite contract as all
      the materials, labour, cost of consumables like electricity,
      water, etc. are to be provided by the party for construction
      of the said projects. The party in his statement dated
      22.09.2015 admitted that they have constructed houses
      for MVDA which were meant for sale to general public and
      his version was endorsed on the website of MVDA, through
      a "Shasanadesh" which stated "आवंटन की तिति से 03 साल में

      भवन का तनमाा ण ... लाभािी द्वारा जमा की गयी धनराशी का 15 प्रतिशि
      वातषाक क्षतिपूतिा आवंटी को दे य होगी," which clearly indicates that
      the project undertaken by MVDA through the party is
      purely commercial in nature. Further Notin.No.25/2012
      dated 20.06.2012, the Central Government, being satisfied
      that it is necessary in the public interest so to do, hereby
      exempts the following taxable services leviable thereon
      under section 66B of the said Act, namely:-
                                              Service Tax Appeal No.70739 of 2018
                              17


S. No. 12. Services provided to the Government, a local.
authority   or    a   governmental      authority          by     way        of
construction,     erection,        commissioning,            installation,
completion, fitting out, repair, maintenance, renovation, or
alteration of -

   (a)   a civil structure or any other original works meant
         predominantly for use other than for commerce,
         industry, or any other business or profession;
   (b)   ......
   (c)   ......
   (d)   ......
   (e)   .....
   (f)   ......

SL. No.13. Services provided by way of construction,
erection, çommissioning, installation, completion, fitting
out, repair, maintenance, renovation, or alteration of,-

   (a)   a road, bridge, tunnel, or terminal for road
         transportation for use by general public
   (b)   a civil structure or any other original works
         pertaining to a scheme under Jawaharlal Nehru
         National Urban Renewal Mission ar Rajiv Awaas
         Yojana;

   SL.N0.14. Services by way of construction, erection,
   commissioning,      or     installation     of     original        works
   pertaining to,-

         (b) a single residential unit otherwise than as a
         part of a residential complex;
         (c) low cost houses up to a carpet area of 60
         square metres per house in a housing project
         approved by competent authority empowered
         under the 'Scheme of Affordable Housing in
         Partnership‟ framed by the Ministry of Housing
         and Urban Poverty Alleviation, Government of
         India;
                                                        Service Tax Appeal No.70739 of 2018
                                18


13.2 It is evident from the work orders/ agreements
supplied by the party, that they rendered the services
of "Work contract service". mainly to the MVDA being a
City    Developer       providing              comprehensive              range       of
services mainly to develop the acquired land for housing
for    different     segment          for           public    and      commercial
property for rent and on sale, scheme is not covered
under     the      definition        of        Government,            Government
Authority or Local Authority and thus the Service Tax is
liable to be paid by the party on the services provided
to the MVDA. Further, there is no specific exemption to
the services provided to the MVDA, which could be
extended to the party against the services provided by
them to the MVDA as per S1.No. 12 of Notification
No.25/2012-ST dated 20.06.2012 as discussed above
i.e. the services provided to the Government, a local
authority or a governmental authority by way of
erection, commissioning, installation, completion, fitting
out. repair, construction. maintenance renovation, Or
alteration of a civil structure or any other original works
meant      predominantly             for        '     use     other       than       for
commerce,          industry,         or        any      other         business        or
profession. Since the services provided by the party are
not predominantly for use other than profession, the
services provided to the MVDA is not covered under the
business     or     provisions            of    Sl.No.12         of     Notification
No.25/2012-ST dated 20.06.2012 for exemption from
service tax. Further, said construction of houses under
the scheme of Shri Kanshiramji Gareeb Awas Yojna and
Economical Weaker Section houses are also not covered
under the Sl.No. 13 of Notification No.25/2012-ST
dated 20.06.2012 and since the work orders does not
mention the carpet area of the said houses nor have the
party been able to prove that the said project is
approved by competent authority empowered under the
'Scheme of Affordable Housing in Partnership‟ framed
                                                       Service Tax Appeal No.70739 of 2018
                                      19


        by     the    Ministry   of    Housing        and      Urban        Poverty
        Alleviation,      Government        of   India         as      has       been
        emphasized in S1.No.14 of the Notfn.No.25/2012-ST
        dated 20.06.2012.

        13.3         Whereas MVDA is a Autonomous body of Uttar
        Pradesh Government which is engaged in business or
        profession by way providing so many service and
        activities and has already been excluded from the
        purview of Negative List in terms of Section 66D of
        Finance Act, 1994. Thus, the services provided by the
        party to the MVDA also appears to be taxable under law
        and Service Tax is liable to be paid by the party on the
        services provided to MVDA."

4.11 Hon'ble Allahabad High Court of Allahabad has in the case
of Greater Noida Industrial Authority has observed as follows:

     "31.    As far as the circular dated 23rd August, 2007
     issued by the Government of India, which has been so
     heavily relied upon by the appellant is concerned, we may
     record that under Clause 032.01, it has been provided that
     the Prasar Bharati Corporation (Doordarshan and All India
     Radio), which has been constituted under the Prasar
     Bharati (Broadcasting Corporation of India) Act, 1990 is
     liable to pay Service Tax for broadcasting services.

     32. Similarly under Clause 999.01 with regard to the
     sovereign/public duties/functions, it has been clarified that
     activities      assigned     to       and    performed               by        the
     sovereign/public authorities under the provisions of any
     law are statutory duties. The fee or amount collected as
     per the provisions of the relevant statute for performing
     such functions is in the nature of a compulsory levy and
     are deposited into the Government account. Such activities
     are purely in public interest and are undertaken as
     mandatory and statutory functions. These are not to be
     treated as services provided for a consideration. Therefore,
     such    activities    assigned        to    be       performed            by      a
                                                        Service Tax Appeal No.70739 of 2018
                                     20


     sovereign/public authority under the provisions of any law,
     do     not   constitute   taxable      services.          Any     amount/fee
     collected    in    such   cases      are    not      to    be     treated        as
     consideration for the purposes of levy of Service Tax.

     33. However, if a sovereign/public authority provides a
     services, which is not in the nature of an statutory activity
     and the same is undertaken for a consideration (not a
     statutory fee), then in such cases, Service Tax would be
     leviable as long as the activity undertaken falls within the
     scope of a taxable service as defined.

     34. Letting of immovable property for consideration,
     which is determined on the basis of offers received from
     public at large by the assessee Greater Noida Industrial
     Development         Authority     is    a    service          provided          for
     consideration and not on payment of statutory fees,
     neither it is a statutory service performed by the assessee.
     It may be that the statute permits such activities of letting
     out of immovable property for augmenting its finances but
     the same cannot be termed as the service in public
     interest nor it is a mandatory or statutory functions of the
     Development Authority. Accordingly such activity of leasing
     do constitute a taxable service, in our opinion."

4.12 In case of Bharat Bhushan Gupta & Co [2016 (44) S.T.R.
195 (P & H)] (relied by the appellant) Hon'ble Punjab And
Haryana High Court has held as follows:

      "4.    Learned Counsel for the petitioner submitted that
     the petitioner is a firm carrying on the business as a
     contractor. It was awarded contract for construction of
     flats for BPL category vide letter dated 26-8-2013. The
     contract is nearing completion. As per the provisions of
     Finance Act, 1994 and Notification No. 25/2012-S.T.,
     dated 20-6-2012 issued by the Government, the service of
     construction, etc., provided to the Government, a local
     authority or a governmental authority is exempted from
     payment       of   service   tax.      The    words          "governmental
                                      Service Tax Appeal No.70739 of 2018
                          21


authority" have been defined in the same notification,
which was clarified later on vide Notification No. 2/2014-
S.T., dated 30-1-2014. The term "original works" has also
been defined in notification dated 20-6-2012. It was
further submitted that the Board has been created under
Haryana Housing Board Act, 1971 (for short, „the Act‟). It
is totally controlled by the Government. There is no private
participation. It is engaged in construction of houses for
the poor and for other customers as well. In addition to
Clause 12 of the notification dated 20-6-2012, it was
submitted that the petitioner may be entitled to exemption
even in Clause 14, which talks about construction of low
cost houses up to a carpet area of 60 square metres. In
the case in hand the construction of houses is for BPL
category, which are of a carpet area less than 60 square
metres.

5.It was further submitted that due to some error,
Clause 12(a), (c) and (f) was omitted from the notification
dated 20-6-2012 vide notification dated 1-3-2015 w.e.f. 1-
4-2015, however, vide Section 102 of the Finance Act,
2016, the exemption was restored again with retrospective
effect from 1-4-2015 till 29-2-2016, with reference to
three clauses, which were omitted from notification dated
20-6-2012. It was further submitted that after Entry 12 in
the notification dated 20-6-2012, Entry 12A was inserted
w.e.f. 1-3-2016 extending the exemption from payment of
service tax in terms of the previous provisions up to 31-3-
2020.

7.It was further submitted that the benefit of         exemption
in terms of notification dated 20-6-2012, being effective
from 1-7-2012, the petitioners in most of the petitions
were awarded contract thereafter will not be liable for
payment of service tax, however, in some cases there is
some small period, which is prior thereto, for which the
petitioners have already paid the due tax or are availing of
                                        Service Tax Appeal No.70739 of 2018
                          22


their appropriate remedy. The dispute in the present bunch
of petitions is only for the period from 1-7-2012 onwards.
Ever since the contract was entered into and the work was
being executed by the petitioner, neither the department
ever issued any notice to the petitioner nor the Board ever
asked for deposit of service tax. The petitioner was
aggrieved against the action of the Board in deducting the
entire amount of service tax even due for the previous
period from the running bills. The grievance is that the
petitioner being not liable to pay the tax, the action of the
Board in deducting the same from the bills of the petitioner
was totally un-called for. Further, it was submitted that in
the case of contractors, the liability to pay the service tax
is 50:50 on the service provider and the recipient. Even if
the clause in the contract is seen, the petitioner would be
liable to pay the service tax of his own share, whereas the
liability, if any, of the Board cannot be passed on to the
petitioner.

17.The service tax has been levied on various services
with amendments made in Finance Act, 1994. The services
on which the tax was levied were added from time to time.
Section 93 of the Finance Act, 1994 enables the Central
Government to exempt any service from payment of tax
by issuing a notification. Notification No. 25/2012-S.T.,
dated 20-6-2012 was issued stating therein that the
Government being satisfied exempts the taxable services
as enumerated in the notification from the whole of the
service tax leviable thereon. If Clause 12 of the notification
dated 20-6-2012 is analysed, exemption from taxation to
the services is provided to :

(i)    Government, a local authority or a governmental
authority;

(ii)   the kind of service being construction, erection,
commissioning, installation, completion, fitting out, repair,
maintenance, renovation, or alteration of;
                                             Service Tax Appeal No.70739 of 2018
                               23


     (iii)   it is meant predominantly for use other than for
     commerce, industry, or any other business or profession.

     18."Original works" has been defined in Clause 2(y) of
     the notification dated 20-6-2012 to mean the meaning as
     assigned to in Rule 2A of the Service Tax (Determination of
     Value) Rules, 2000.

     19.On a plain reading of the notification dated                  20-6-
     2012, in our view, the service being provided by the
     petitioners would clearly fall in the exemption clause, as
     the Board is a governmental authority having been set up
     under a State Act, i.e., Haryana Housing Board Act, 1971.
     It is wholly controlled by the State Government. BPL
     houses constructed by the petitioners are meant for
     residential purpose and not for commerce, industry or any
     other business or profession.

     20.Similar issue came up for consideration before a
     Division Bench of Patna High Court in Shapoorji Paloonji
     and Company Pvt. Ltd.‟s (supra), where the contact was
     for construction of administrative block in Indian Institute
     of Technology set up under the Institutes of Technology
     Act, 1961. Indian Institute of Technology was held to be a
     governmental authority and the contract for construction
     was opined to be falling in the exemption clause. The
     notice issued for levy of service tax was quashed.

     21.In view of our aforesaid discussion, it can safely                 be
     opined that for the kind of contract entered into between
     the petitioners and the Board, no service tax is leviable,
     hence, the action of the Board in deducting part of the
     service tax, though payable in the hands of the Board, if
     tax is leviable, from the bills of the petitioners is declared
     to be illegal.

4.13 We also note that all the work orders in respect of the
construction of the houses are dated prior to 01.07.2012, hence
we do not find any merits in the submissions made by the
appellant with regards to admissibility of exemption under
                                                 Service Tax Appeal No.70739 of 2018
                                   24


notification No 25/2012-ST or on the reliance placed by the
appellant on this decision. From the facts of the case as recorded
in the table computing the demand appellant has received
following amounts post 01.07.2012 on which service tax demand
is meager as indicated in table below:

     Financial Year           Receipt    Service Tax Demanded
     2012-13 (Jul-Mar) 2373829                    55917
     2013-14                  884696              20839
     Total                    3258525             76756

Hon'ble Punjab and Haryana High Court in the above case was
concerned with payment of service for the period subsequent to
01.07.2012 and have concluded that service tax in respect of
these services was exempted as per notification No 25/2012.

4.14 In case of Ganesh Yadav [2017 (6) GSTL 428 (T-All)]
following has been held:

      "3.    Being      aggrieved, the Revenue is in appeal before
      this Tribunal. On the ground that the said service is
      taxable under sub-clause (zzzza) of Section 65(105)
      wherein it is provided as follows :-

      "For the purpose of this sub-clause, „works contract‟ means
      a contract wherein :-

      (i)    transfer    of   property   in   goods    involved        in    the
      execution of such contract is leviable to tax as sale of
      goods, and

      (ii)   such contract is for the purposes of carrying out -

      (c)    construction of a new residential complex or a part
      thereof......"

      It is further contended by the Revenue that the Varanasi
      Development Authority was the service receiver and the
      construction was not for the personal use of party. The
      party (respondent) was liable to pay Service Tax under
      Works Contract Service. The respondent had himself
      admitted that he was providing service of work contract to
      Varanasi Development Authority. As such there was no
                                               Service Tax Appeal No.70739 of 2018
                              25


dispute    with    regard    to    classification     of     the     service
rendered. The respondent claimed exemption on the basis
of the nature of the project i.e. for construction of houses
under Manyavar Kanshi Ram Saheri Garib Avas Yojna, was
not acceptable under Notification No. 6/2011, dated 1-3-
2011 wherein exemption to construction of residential
complex and finishing and completion services thereto is
for specified projects, under "Works Contract Services".
The Notification specifically provides exemption to (a)
construction of new residential complex or part thereof, (b)
completion      and   finishing    services     of    new       residential
complex or partly thereof under Jawaharlal Nehru Urban
Renewal Mission and Rajiv Awas Yojana, from the whole of
the Service Tax leviable thereon. It is contended by the
Revenue that there is no specific exemption given to the
Government of U.P. for Manyavar Kanshi Ram Saheri Garib
Avas Yojna. It is further contended that activity of
constructing houses for economically weaker sections for
Varanasi Development Authority is taxable under the
category "Works Contract Service".

4.Heard the parties.

5.We find       that the issue in itself is incorrect. Larger
Bench of this Tribunal in the case of Lanco Infratech Ltd. v.
CC, CE & ST - (2015) 38 S.T.R. 709 (Tri. - LB) has held
that such activity which was not taxable prior to 1-6-2007
under     the     category   of     Commercial          and      Industrial
Construction      continue    to    be   non-taxable           under       the
category of Works Contract Service from 1-4-2007. Further
we find that under similar facts and circumstances, a Co-
ordinate Bench of this Tribunal in the case of CCE v. Manoj
Kumar Singh Appeal No. ST/70135/2015 vide a stay order
dated 19-5-2016 was pleased to reject the stay application
filed by Revenue under the similar facts and circumstances
where the respondent Manoj Kumar Singh had constructed
civil structures, repairing, doing alteration, renovation or
                                           Service Tax Appeal No.70739 of 2018
                           26


restoration of old structures, completing and finishing job,
installation of electrical and electronic devices, etc., under
contract and work orders of VDA, Varanasi. It was
observed that prima facie no service tax is leaviable on
construction of low cost housing. It is also apparent that
the flats constructed under the scheme are neither
intended for commerce or industry but for the welfare of
the weaker sections of the society. A reference was also
made to precedent decision in the case of ECP Housing
(India) Pvt. Ltd. v. Commissioner of Central Excise, Nasik
reported at 2013 (30) S.T.R. 703 wherein it was held that
the demand under commercial and industrial construction
for contract of construction divided into two parts of
construction of stadium and construction of shopping
complex around stadium held activity of construction of
sports complex/stadium cannot be termed as commercial
and industrial construction. We also agree with finding of
learned Commissioner (Appeals) holding that the activity
for constructing houses by the appellant for economically
weaker sections under works allotted by the Varanasi
Development Authority under the scheme of Government
of U.P., the activities is neither taxable under works
contract    services     nor      under        Construction              of
Complex/Commercial or Industrial Construction Services
more   particularly    under    the   exclusion       clause       which
provides that construction classifiable under the category
of residential complex service does not include a complex
which is constructed by a person directly engaging any
other person for designing or planning of the layout, and
the construction of such complex is intended for personal
use as residence by such person and personal use have
been further explained as including or permitting the
complex for use as residence by another person on rent or
without consideration. Accordingly, we dismiss the appeal
of Revenue."
                                                     Service Tax Appeal No.70739 of 2018
                                      27


4.15 This decision also do not decide the issue in hand. This
decision      holds    that     Complex/Commercial                  or     Industrial
Construction Services excludes the complex which is intended for
person use as residence by such person and personal use have
been further explained as including or permitting the complex for
use as residence by another person on rent or without
consideration. In the present case it is not evident that these
house        being    constructed    for    MVDA        fulfilled        the    above
requirement. Show cause notice specifically states that the
houses were being sold against a consideration.

4.16 Appellant has claimed that the said service provided in
respect of construction of low cost housing are exempt from
payment of service as CBEC Circular No 80/10/2004 dated
17.09.2004 read along with Circular 123/5/2010-TRU dated
24.05.2010. We would like to point out that on CBEC website
there is no circular marked 80/10/2004 dated 17.09.2004. Might
be to counsel for appellant has generated the Circular No,
because circular No 80/1/2005 is dated 10.08.2005. Definitely
there is communication dated 17.09.2004, in which para 13.1
reads as follows:

        13.1 Services provided by a commercial concern in relation
        to construction, repairs, alteration or restoration of such
        buildings, civil structures or parts thereof which are used,
        occupied or engaged for the purposes of commerce and
        industry are covered under this new levy. In this case the
        service is essentially provided to a person who gets such
        constructions etc. done, by a building or civil contractor.
        Estate builders who construct buildings/ civil structures for
        themselves (for their own use, renting it out or for selling
        it   subsequently)     are   not      taxable     service         providers.
        However,        if    such     real      estate         owners           hire
        contractor/contractors,       the     payment        made          to    such
        contractor would be subjected to service tax under this
        head. The tax is limited only incase the service is provided
        by a commercial concern. Thus service provided by a
                                                             Service Tax Appeal No.70739 of 2018
                                           28


      laborer engaged directly by the property owner or a
      contractor who does not have a business establishment
      would not be subject to service tax.

By Circular No 123/5/2010-TRU dated 24.05.2010 following has
been clarified:

      S.No.   Activity                                   Status
      1.      Shifting of overhead cables/wires for      Not a taxable service under any
              any reasons such as widening/              clause of sub-section (105) of
              renovation of roads                        section 65 of the Finance Act,
                                                         1994
      2.      Laying of cables under or alongside        Not a taxable service under any
              roads                                      clause of sub-section (105)of
                                                         section 65 of the Finance Act,
                                                         1994
      3.      Laying of electric cables between          Not a taxable service under any
              grids/sub-stations/transformer             clause of sub-section (105)of
              stations en route                          section 65 of the Finance Act,
                                                         1994
      4       Installation of transformer/ sub-          Taxable       service,     namely
              stations undertaken independently          Erection,     commissioning    or
                                                         installation services [section 65
                                                         (105] (zzd].
      5.      Laying of electric cables up to            Not a taxable service under any
              distribution point of residential or       clause of sub-section (105)of
              commercial localities/complexes            section 65 of the Finance Act,
                                                         1994
      6.      Laying of electric cables beyond the       Taxable       service,    namely
              distribution point of residential or       commercial        or    industrial
              commercial localities/ complexes.          construction' or 'construction of
                                                         complex' service [section65(105)
                                                         (zzq)/ (zzzh)], as the case may
                                                         be.
      7.      Installation of street lights, traffic     Taxable       service,     namely
              lights flood lights, or other electrical   Erection,     commissioning    or
              and electronic appliances/devices or       installation services [section 65
              providing electric connections to          (105] (zzd].
              them
      8.      Railway electrification, electrification   Not a taxable service under any
              along the railway track                    clause of sub-section (105)of
                                                         section 65 of the Finance Act,
                                                         1994

4.17 We are in the present case concerned with demand made
in respect of construction of 256 Houses under Shri Kanshiramji
Gareeb Awas Yojna awarded on 23.10.08, construction of 160
Houses under Shri Kanshiramji Gareeb Awas Yojna awarded on
07.07.2010, construction of 96                    EWS Houses              awarded on
06.10.2009 and construction of 144 EWS Houses awarded on
19.07.2010. Appellant is totally silent in respect of the issue in
dispute. The circular cited are not in respect of issues for which
this demand has been made. Appellant has never stated that
                                                 Service Tax Appeal No.70739 of 2018
                                 29


this demand is made in respect of "Road Repair Construction for
MVDA and for repair construction of drain for MVDA. Further we
also note that contract in respect of

    repairing of drain was approved on 25.10.2008, which was
      to be completed by 26.02.2009.
    construction of road from bus stand to Hindu Inter College
      Nand    Gaon   Marg   in   Kosi   Kalan      was      approved           on
      27.12.2007
    strengthening of 100 wide Master Plan Road 18 mtr. Wide
      and repairing of S W drain at Chaitanya Vihar I & II was
      approved on 05.12.2008 and was to be completed by
      30.04.2009

From the perusal of the above it is quite evident that all these
contracts are in respect of the work which were completed much
prior to period of demand and hence we are not in position to
consider these works done by the appellant in respect of the
services provided during the period of demand.

4.18 From the tender documents, submitted in respect of
Rukmini Vihar Yojana, it is evident that tender document do not
specify that these House are meant for free distribution to poor.
It only specifies that they are meant for low income group. We
do not find any evidence to show that these activities were taken
in respect of any scheme which falls under the category of
exempted scheme which has been approved in the manner
provided by the entry no 13 or 14 of the Notification No
25/2012-ST.

4.19 It is now settled law that it is for the person claiming any
exemption to show that he falls within the purview of the
exemption claimed. Hon'ble Supreme Court has in case of Dilip
Kumar & Company [2018 (361) E.L.T. 577 (S.C.)] held as
follows:

      52. To sum up, we answer the reference holding as under
      -

Service Tax Appeal No.70739 of 2018 30 (1) Exemption notification should be interpreted strictly; the burden of proving applicability would be on the assessee to show that his case comes within the parameters of the exemption clause or exemption notification.

(2) When there is ambiguity in exemption notification which is subject to strict interpretation, the benefit of such ambiguity cannot be claimed by the subject/assessee and it must be interpreted in favour of the revenue.

(3) The ratio in Sun Export case (supra) is not correct and all the decisions which took similar view as in Sun Export case (supra) stands overruled.

4.20 Thus we do not find any merits in the submissions made by the appellant in respect of the services provided by them to MVDA.

4.21 Appellant have not contested the demand on limitation either in appeal or at the time of the argument. However, we find that the appellant had suppressed the receipts from the M/s IOCL and MVDA with intent to evade the payment of tax.

4.22 Order in original records as follows for invoking extended period of limitation, demanding interest and for imposition of penalty under Section 78 of the Finance Act, 1994 "44. The party submit that the extended period of limitation is not invokable against them in this case. This is not acceptable in view of the facts discussed in above paras. The party while providing taxable services did not get themselves registered with the department within one month of commencement of his business and got themselves registered late as on 08.08.2012. The party has also not filed five Nos. of periodical ST-3 returns for the period 2010-11 to 2012-13 (April-June). It was during the course of the enquiry conducted by the department that the facts of the case got un-earthed. This fact clearly makes me to hold that this is the case of deliberate Service Tax Appeal No.70739 of 2018 31 suppression and misrepresentation of facts with intention to evade payment of tax by the party, in as much as, the party had knowingly and willingly attempted to escape from payment of service tax. I have noticed that the government since beginning had placed full trust on the service providers so far service tax is concerned and accordingly, measures like self-assessments etc., based on mutual trust and confidence have been introduced. Further, a taxable service provider has not been required to maintain statutory or separate records under the provisions of Service Tax Acts/ Rules, as considerable amount of trust has been placed on the service providers and private records maintained by them for normal business purposes have been accepted for all the purposes of Service tax. All these operate on the basis of honesty of the service provider therefore, the governing statutory provisions create an absolute liability when any provision is contravened or there is a breach of trust placed on the service provider. Further bonafide intention cannot exist in thin air, but needs to be supported by positive action of the assessee. Here it is otherwise. From the evidence, it is clear that the party have not correctly assessed their taxable value. They also failed to declare the value in ST-3 Returns for the taxable services rendered by them, in as much as, they did not file the periodical ST-3 returns for the period 2010-11 to 2012-13 (April-June) and also did not pay proper service-tax at appropriate time due on the taxable service rendered by them by disregarding to the requirements of law and breach of trust deposed on them.

44.1. Thus, the facts discussed above clearly confirm that the party had deliberately and willingly not paid proper service tax with a motive to evade payment of service tax. Hence, in my opinion, the provisions for recovery of service tax for extended period in terms of proviso to the sub-section (1) of Section 73 of the Finance Act, 1994, have/ rightly been invoked in the matter. Accordingly, I Service Tax Appeal No.70739 of 2018 32 hold that the proviso-to Section 73(1) mentioned supra, has rightly been invoked for recovery of service tax. I therefore hold that the said charge of suppression of fact has rightly been proposed in the show cause notice and accordingly the provisions of extended period in terms of proviso to Section 73(1) of the Finance Act, 1973, are liable to invoked in the present matter.

44.2. After discussing the entire issues and recording the findings on each issue, I find in preceding paragraph that the party is liable to pay service tax on Work Contract & Repair & Maintenances under Work Contract provided bv them to M/s. IOC Ltd. and MVDA. Accordingly, I have calculated the service tax liability that is to be discharged by the party. applicable from time to The taxable amount after allowing abatement and service tax involved thereon at the rates time is Rs.44,87,860/- [Rs. 12,22,441 (IOC)+Rs.32,65,419 (MVDA)].

The amount on which service tax is not payable pertains to account of "Storm Water Drainage Work" during the financial year 2010-11 & 2011-12 from amount received on M/s L&T and also the amount received from M/s Brij Housing and Developers, Mathura for construction of individual residential house, which actually were not taxable services. The service tax involved on these non-

taxable amounts comes to Rs.3,20,141/-

(Rs.2,76,563(L&T)+Rs.43,578(Brij Housing)), the demand in respect of which is liable to be dropped. Thus, in light of the facts, I hold that out of total demand of Rs.48,08,001/- mentioned in the impugned notice, the demand of service tax of Rs.44,87,860/ - is liable to be confirmed, whereas the demand of service tax of Rs.3,20,141/- is liable to be dropped. Further in view of the above, I am inclined to hold that the charges levelled against the party in the show cause notice are proved. On perusal of the case laws cited and relied upon by the party Service Tax Appeal No.70739 of 2018 33 in their support, I have noticed that the same are not identical or relevant to the issue addressed, in the impugned notice therefore the amount of Rs. 44,87,860/- including Edu. Cess and SHE Cess) is liable to be confirmed under Section 73(1) (proviso) along witt applicable interest Section 75 of the Finance Act, 1994.

45. Further, on the question of payment of interest on such declared dues, I am of the opinion that the liability to pay the Service Tax has been confirmed against the party, then, there can be no immunity from Payment of appropriate interest on such Service Tax liability. I notice that it is an inbuilt provision that in the event of failure of timely payment of the tax amount into the credit of the Government exchequer, the same has to be paid alongwith the interest. I find that Hon'ble CESTAT in the case of Sree Vadivambigai Textile Mills Ltd. Vs. CCE [2005]1 STT 72(Chennai-CESTAT) held that "levy of interest under section 75 is mandatory and no leniency can be shown merely because appellant has been declared as a sick company". I also find that the Hon'ble CESTAT. in the case of INMA International Security Academy (P) Ltd. Vs. CCE [(2005)1 STT 31(Chennai-CESTAT] held that "the liability to pay interest at prescribed rates was inescapable as the law did not confer any discretion in the matter of levying interest." Therefore, in` view of the settled law, the party is required to pay the interest at the applicable rate under the provision of Section 75 of the Finance Act, 1994 on the amount of Service Tax, which they have failed to pay on due date, till its actual date of payment.

46. As regards proposal to impose penalty upon the party under Section 78 of the Finance Act, 1994, after considering the facts discussed in the foregoing paras, I am of the view that the immunity from penalty can be granted, only if the party had not deliberately acted in deliance of law. In this case, the facts abundantly suggest Service Tax Appeal No.70739 of 2018 34 that the party had deliberately suppressed the gross receipt against provision of taxable services and have not obtained service tax registration with in stipulated period and also not fled their ST-3 returns for the period from 2010-11 to 2012-13 (April-June). Further, the party has not paid Service Tax, due on the taxable service provided by them during the concern period, by deliberately withholding the crucial information, and did not disclose- the material facts to the department, which is nothing but a wilful attempt to suppress the facts with intent to evade payment of due Service Tax. It is on record that this detection of short payment/ non payment of Service Tax came into notice, on behest of the department who got conducted the enquiry against the party. The said short payment of Service Tax cannot be equated with the mere failure on the part of the party. It was rather an act of deliberate and gross indulgence to evade the Payment of Service Tax by the party. It is a fact on record that the party did not sought registration timely. These facts clearly confirm the party's intention to evade payment of Service Tax, and once, such intention gets proved, the presence of pre-requisite for imposition of penalty under Section 78 of the Finance Act, 1994 gets confirmed. This cannot be treated as mere ignorance on the part of the party. ...

As appellant has not stated anything against the above findings recorded in the order in original either before the first appellate authority or before us we uphold the said findings.

4.23 In view of discussions as above, we summarize our findings as follows:

a. Demand made in respect of M/s IOCL needs to be reworked out after reducing the receipts in respect of the work orders relating to supply of sand and horticulture services provided. b. Demand in respect of services provided to MVDA is upheld.
Service Tax Appeal No.70739 of 2018 35 c. Penalty under Section 78 is upheld but shall stand reduced by the amount of demand reduced in case of receipts of M/s IOCL.
d. Demand for interest under Section 75 and penalty imposed under Section 77 (2) is upheld. e. Late Fee imposed under provisions of Section 70 read with Rule 7C of The Service tax Rules, 1994 is upheld.

5.1 Appeal is partly allowed and matter is remanded to the Original Authority for requantifiaction of demand as indicated in para 4.23.

5.2 Matter to be decided in remand proceedings within three months from receipt of this order.

(Order pronounced in open court on-16 October, 2025) (SANJIV SRIVASTAVA) MEMBER (TECHNICAL) (ANGAD PRASAD) MEMBER (JUDICIAL) akp