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CESTAT allowed the appeal and set aside the impugned adjudication, holding that the Belapur Commissionerate lacked jurisdiction to issue the SCN. The Tribunal found the appellants were duly registered and assessed for taxable cosmetic and surgical services under the Bhiwandi Commissionerate, and their Belapur "non-assessee" registration pertained solely to a different purpose and did not confer competence to initiate service tax proceedings. Consequently, actions taken by Belapur based solely on the non-assessee registration were without locus standi and unsustainable, and the confirmed demands in the impugned order were quashed.
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