AI Drafter - (New and Powerful) 
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter. 
TaxTMI 
TaxTMI 
2026 (4) TMI 520
X X X X Extracts X X X X
X X X X Extracts X X X X
....d the present to Miscellaneous Applications to introduce additional grounds in terms of Rule 10 read with Rule 41 of the Customs, Excise & Service Tax Appellate Tribunal Procedure Rules, 1982, to include additional grounds in their appeal, memo, and additional documents in terms of Rule 23 of the said rules. 2. The brief facts are that the appellant was sub-contractor to Era Constructions (India) Ltd., Gannon Dunkerley & Co. Ltd and Apex Build Sys Pvt Ltd for fabrication and erection activities of structural steel at several sites as per work orders. Investigations were launched following which show cause notice dated 22.4.2016 for the period 2010-11 to 2014-15 and show cause notice dated 11.4.2018 was issued for the period 2015-16 alleg....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... the appellant. 4. Learned Authorised Representative submitted that the appellant cannot take new grounds which had not been agitated earlier by them before the original adjudicating authority. In this context, he relied on the Tribunal's decision in Gannon Dunkerley & Co. Pvt Ltd vs Commissioner of C.Ex & S.T.(Adj), Delhi-2020(43) GSTL 183(Tri. Del). 5. We have heard the learned Counsel for the appellant and the learned Authorised Representative for the Department. 6. We have perused memorandum of appeal, and the grounds of appeal taken before the original Authority. In this context, we note that the only ground that was taken, was that the applicant being a sub-contractor was not liable to pay the service tax which had already be....