Completion and finishing services supported only partial pre-deposit relief in a service tax dispute over industrial construction classification.

Completion and finishing services, including lining and tiling of ducts, were treated as prima facie distinct from industrial construction for pre-deposit purposes. On that basis, a full waiver of pre-deposit of service tax and penalty was not justified. Partial waiver was considered appropriate, subject to compliance with the directed deposit. Upon such compliance, the balance demand, interest and penalty were waived, and recovery of those amounts was stayed pending the appeals.

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Issues: Whether full waiver of pre-deposit of service tax and penalty was warranted in a dispute concerning completion and finishing services vis-a -vis industrial construction.

Analysis: The activities carried out were found, prima facie, to be completion and finishing services such as lining and tiling of ducts. On that basis, a total waiver of pre-deposit was not justified, and only partial waiver was considered appropriate.

Outcome: The assessee was directed to make a partial pre-deposit of service tax, with waiver of the balance demand, interest and penalty upon compliance, and recovery of those amounts was stayed pending the appeals.

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