TaxTMI 
TaxTMI 
2025 (6) TMI 449
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....dingly, the Show Cause Notice was issued demanding Rs.15,86,545/-. The Appellant did not file their reply nor they appeared for Personal Hearing. The Adjudicating Authority confirmed the demand by Ex-Parte order vide Order-In-Original dated 12.07.2022. Being aggrieved, the Appellant has filed their appeal before the learned Commissioner (Appeals). Before him they submitted that they have been registered with the Service Tax Department under the category of 'supply of manpower'. They submitted that since they have been providing services of manpower to various corporates, the Service Tax, if any, is required to be discharged by the recipient of service on reverse charge basis. They provided all the documentary evidence in the form of agreeme....
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....n 28.12.2020 merely based on Income Tax Return and Form 26AS. He relied on the case law of this Bench in the case of Pappu Crane Service V/s Commissioner, C.E. & S.T., Lucknow in Service Tax Appeal No.70707 of 2018 Final Order No.71246 of 2019. Accordingly, he prays that the appeal may be allowed. 5. The learned Authorized Representative for the Revenue submits that the learned Commissioner (Appeals) has gone through the documentary evidence and has held that the Appellant is not providing 'manpower services'. He submits that since the Department had to undertake detailed verification, the Show Cause Notice was issued by invoking the extended period provisions. Accordingly, he justifies the impugned order and prays that the present appeal ....
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....tomers by using the cranes owned by him. The said job-work was being done by him on time basis i.e. weekly, daily & monthly etc. Further, the figures reflected in balance sheet are also relatable to construction of road etc. which are not a taxable activity. Otherwise also, he submitted that the demand raised by invoking the longer period of limitation is solely based upon the profit and loss account and 26AS form submitted with the Income Tax Authorities which has been held to be as not proper by the Tribunal in various decisions. Reference stands made to the decision of Hon'ble High Court in the case of M/s Firm Foundation and Housing Pvt. Ltd. Vs Principal Commissioner of Service Tax, Chennai (Madras) pronounced on 06.04.2018 in Writ Pet....