2026 (2) TMI 473

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....l of the appellants by dropping the penalties under Sections 76, 77 & 78 of the Finance Act, 1994. 2. Briefly stated facts of the present case are that the appellants are engaged in providing 'Security Agency Services' to various banks and other such organizations. The allegation of the department is that the appellants are not paying service tax under the category of 'Security Agency Services' and have not got registered with the service tax department. Accordingly, a show cause notice was issued to the appellants proposing to recover the service tax under proviso to Section 73(1) of the Finance Act, 1994 by invoking the extended period of limitation, along with interest under Section 75 of the Act and penalties under Se....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....in it has been clarified that the activities assigned to and performed by the sovereign public authorities under the provisions of law are statutory duties and the fee/amount collected as per the provisions of the relevant statute for performing such functions are in the nature of compulsory levy and are deposited into Government Treasury, therefore, no service tax is payable. 5. Further, we find that this issue is no more res integra and has been decided by the Tribunal in various cases. This Tribunal vide its earlier Final Order in the case of Senior Superintendent of Police Ferozepur vs. CCE & ST, Ludhiana [Final Order No. 61401/2025 dt. 17.09.2025 in Appeal No. ST/60852/2018] has considered the identical issue and has held as under: ....