TMI Blog2012 (8) TMI 205X X X X Extracts X X X X X X X X Extracts X X X X ..... filed for waiver of pre-deposit of Service Tax liability of Rs.3,79,280/-, interest thereof and equal amount of penalty. 2. Heard both sides and perused the records. 3. The above said Service Tax amount and consequent penalties have been confirmed by Commissioner as a revisionary authority on a revision of order of 1st adjudicating authority, who has dropped the Show Cause Notice. The original ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dt.21.4.03 was addressed by the appellant to the Superintendent, Central Excise, having jurisdiction over his factory, about the activity conducted by them on the tender accepted by ONGC for laying down of pipelines for transportation of gas. 5. Ld.A.R. appearing for the Revenue, on the other hand, would submit that the activity undertaken by the appellant would fall under the category of Commerc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ivities being carried out by him. Despite this, revision authority has not called for any information nor gave any direction/ suggestion to the appellant to classify such activity of manufacture. 7. According to us, prima facie, the matter seems to be hit by limitation. Be that as it may, we find that the adjudicating authority has considered this activity of the appellant as being not liable to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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