Public sector undertaking's service tax demand upheld but penalties waived. CENVAT credit eligibility cited for revenue neutrality.

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....Service tax demand against public sector undertaking upheld, but penalties waived u/s 80 of Finance Act, 1994 considering revenue neutrality as service tax paid would be eligible for CENVAT credit, following HUDCO case; appeal dismissed as no substantial question of law arose from discretionary order based on factual finding of revenue neutrality.....