2026 (3) TMI 910

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....the activity of Construction of Residential Complex Service having more than 12 dwelling units. The Revenue alleging that the appellant had not discharged service tax, issued show-cause notice demanding service tax and denying the cenvat credit during the relevant period of dispute for the period from October 2006 to September 2009. The Commissioner in the impugned order confirmed the service tax amount and also disallowed ineligible cenvat credit against which this appeal is being filed. 2. The Learned Counsel submits that the issues involved in the present appeal are regarding liability to pay service tax under the category of 'Construction of Residential Complex' during the relevant period; and also the liability to pay service tax un....

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....establishment in India and abroad as separate persons. Relying on the following decision, it is submitted that the services rendered for their own self cannot be liable to service tax. * Steel Authority of India Ltd. Vs. CST New Delhi 2020 (4) TMI 346 CESTAT Delhi * CCT. Bangalore Vs. Indo MIM Tec Pvt. Ltd. 2024 (12) TMI 1617 CESTAT, Bangalore. * Cades Digitech Pvt. Ltd. Vs. CCT. Bangalore 2022 (1) TMI 1408 CESTAT New Delhi. 2.4 With regard to limitation, it is submitted that since all the issues revolve around interpretation, therefore, the question of suppression does not arise. It is also submitted that against the appellant's sister concern at Trivandrum, identical demands were raised for the very same peri....

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....f. 01.07.2010 and the Board Circulars dated 29.01.2009 and 10.02.2012, the liability to pay service tax by the appellant prior to 01.07.2010 cannot be sustained. The various decisions relied upon by the appellant have also upheld the appellant's claim that they are liable to pay service tax only w.e.f. 01.07.2010 onwards. Hence, the demand to this extent confirmed by the Commissioner is liable to be set aside. 5. With regard to 'Sponsorship Services', we find that the payment of Rs.1,90,050/- was made to their business partner/ associate towards establishing/renewal of the legal existence of the appellant's place of business at Dubai. Since, these payments are not towards any sponsorship but made towards legal compliances, we do not find....