2017 (4) TMI 1051

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.... Tax Department for the purpose of discharging service tax. Certain enquiries were conducted by the officers of DGCEI Regional Unit, Raipur in July, 2010. On completion of the enquiry, proceedings were initiated against the appellant by show cause notice dated 24/12/2012, to demand and recover and amount of Rs. 2,27,40,246/- towards their service tax liability for the period 2006-2007 to July, 2012 under the category of consulting engineering service. The said amount was said to have been representing the service tax collected by the appellant from their consumers and, as such, the demand was made under Section 73A (3) readwith Section 73 (2) of Finance Act, 1994. An amount of Rs. 2,00,67,509/- already paid by the appellant is sought to be ....

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.... (a) Diamond Cements vs. CCE, Bhopal dated 16/11/2016 cited as 2017 - TIOL - 1264 - CESTAT - DEL. ; (b) Devang Paper Mills Pvt. Ltd. vs. Union of India dated 30/11/2015 cited as 2016 (41) S.T.R. 418 (Guj.) ; (c) Arcadia Share & Stock Brokers Pvt. Ltd. vs. CCE & C, Goa dated 13/06/2013 cited as 2013 (7) TMI 330 - CESTAT Mumbai ; and (d) Pepsico India Holding Pvt. Ltd. vs. CE, Allahabad dated 15/04/2010 cited as 2010 (20) S.T.R. 552 (Tri. - Del.). 3. The learned AR reiterated the findings recorded in the impugned order. She further submitted that the appellants were engaged in providing various taxable services. The service tax paid under technical inspection and certification agency service cannot be adjusted towards liability und....