9911796707
TMI Blog2025 (2) TMI 377X X X X Extracts X X X X X X X X Extracts X X X X ..... gaged in providing following services to M/s Indian Oil Corporation Ltd and M/s Hindustan Petroleum Corporation Ltd (hereinafter referred as "oil companies"):- * commercial civil construction work, * installation/commissioning of tanks/dispensing units, * repair & maintenance work of tanks/pipes etc, * transportation of material with reference to the other works. 2. On scrutiny of the records of the assessee, the department issued two SCNs dated 18.04.2012 and 08.04.2013, covering the period October 2006 to March 2012, proposing to demand of service tax of total amount of Rs.1,46,36,336/- (Rs.1,05,07,096/- & Rs.41,29,240/- in each SCN respectively) under various headings. The learned Commissioner, vide the impugned order dated 02.0 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... indivisible contracts under different heads than 'Works Contract Service'. She further submits that before 01.06.2007 also, the works undertaken were not chargeable to service tax. She relies on the following decisions: * Commissioner vs. Larsen & Toubro Ltd and others - 2015 (8) TMI 749 Supreme Court * Janta Electric Store vs. CCE & ST, Rohtak - 2025 (1) TMI 678 CESTAT Chandigarh * Bestech India Pvt Ltd vs. CST, Delhi - 2025 (1) TMI 542 CESTAT Chandigarh * Deepak Builders vs. CCE & ST, Ludhiana - 2024 (12) TMI 1143 CESTAT Chandigarh * T&T Projects Limited vs. CCE & ST, Dibrugarh - 2024 (11) TMI 1132 CESTAT Kolkata * Bajrang Lal Gupta vs. CCE, Gurgaon - 2023 (6) TMI 246 CESTAT Chandigarh * Srishti Constructions vs. CCE & ST, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ies on the following decisions: * Anil Kumar Garg vs. CCE & ST, Chandigarh-II - 2024 (12) TMI 354 CESTAT Chandigarh * Janta Electric Store vs. CCE & ST, Rohtak - 2025 (1) TMI 678 CESTAT Chandigarh * Austees Hydro Power And Construction Co Pvt Ltd vs. CCE & GST, Shimla - 2025 (1) TMI 346 CESTAT Chandigarh 5. Shri Aneesh Dewan, the learned Authorized Representative for the Revenue reiterates the findings of the impugned order as for as the assessee's appeal is concerned and the grounds of appeal as for as the Revenue's appeal is concerned. 6. Heard both sides and perused the records of the case. 7. The learned Commissioner vide impugned order finds that the demands in both SCNs were raised without considering the applicable abatement ..... X X X X Extracts X X X X X X X X Extracts X X X X
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