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TMI Blog2018 (1) TMI 1486X X X X Extracts X X X X X X X X Extracts X X X X ..... it shows that the appellant was aware of the levy of service tax which they have not discharged within the stipulated time. Therefore, the submission of the Learned Counsel of the bona fide belief on the part of the assessee cannot be accepted. The Commissioner (Appeals) had modified the Adjudication Order and imposed penalty of equal amount under Section 78. In such situation, the benefit und ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are that the appellant is engaged in rendering erection, commissioning or installation service and Works Contract Service to M/s. Central Mining Planning and Design Institute, Ranchi and M/s. Central Coalfields Limited, Ranchi. 2.2 Show Cause Notice dated 24-4-2012 was issued alleging that they have evaded the payment of Service Tax for the period October, 2006 to March, 2012. 2.3 The ad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lief that the services rendered to the Public Sector Undertakings are not liable to pay Service Tax. It is also submitted that the appellant had not collected the Service Tax from their customers. The Learned Counsel also cited various decisions. 5. I find that there is no dispute on tax liability which they have discharged after detection by the department. The contention of the appellant is t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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