Refund Claim Denied: Services to SOLCIL Not Exempt Under Notification 25/2012-ST or Finance Act's Negative List.

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....Refund claim rejected by adjudicating authority on grounds that services provided by appellant to SOLCIL did not qualify for exemption under Notification No. 25/2012-ST or negative list in Section 66D of Finance Act, 1994. Documents showed appellant provided services only to SOLCIL, raised invoices, received payment, and paid service tax under business auxiliary service category. Neither notification nor circular provided exemption for business auxiliary services rendered by appellant to SOLCIL. Both parties located in taxable territory, hence service tax correctly levied. Appellant did not provide auxiliary education services to educational institutions to claim exemption. Authorities concluded exemption claimed by appellant inadmissible. Appellant failed to clarify nature of transaction. No illegality in rejecting refund claim. Impugned order upholding rejection of refund claim.....