2025 (1) TMI 1321

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....unicated to the appellant vide letter dated 21.02.2007 thereby indicating that the sub-work of electrification for the Civil Court Complex at Pondicherry executed by them was liable to service tax under "Erection, Commissioning or Installation Service" [ECIS for short]. The above facts have been captured at para 02.01 of the Show Cause Notice dated 22.10.2012. Thereafter, through various letters/reminders dated 18.07.2011, 27.03.2012, 01.06.2012 and 11.07.2012 it appears that the Revenue requested the payment details through the Superintendent of Central Excise, Erode to which, vide letter dated 11.09.2012 the appellant appears to have furnished a copy of the Agreement wherein the scope of the work order was mentioned. It is only thereafter....

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....y filed by the notice, however, in the OIO No. 26/2013 ST-ADC, dated 29.07.2013 has confirmed the proposed demands. Strangely, in the said order the Additional Commissioner has not whispered anything about the earlier letter of the Superintendent dated 21.02.2007 anywhere in the OIO thereby ignoring material particulars on record, but also the plea of the appellant insofar as merits as well as its defense against invoking of the extended period of limitation are concerned. Naturally, aggrieved by the demands in the above OIO, the appellant appears to have preferred first appeal before the Commissioner (Appeals) and, the First Appellate Authority vide OIA No. 38/2014-ST, dated 28.01.2014 also having upheld the demands thereby rejecting their....