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TMI Blog2024 (11) TMI 262X X X X Extracts X X X X X X X X Extracts X X X X ..... ent Treatment Plant during the material period pertains to various parties which are as below : M/s Krishak Bharti Corporation Limited, PO Kribhco Nagar, Surat M/s Oil & Natural Gas Corporation Ltd., Hazira Gas Processing Complex, ONGC Nagar, Surat M/s Chennai Petroleum Corporation Ltd., Chennai M/s Common Effluent Treatment Plant (Thane-Belapur) Association, Khairane, Thane-Belapur Road, Navi Mumbai M/s Malad Manufacturers Association, Common Facility Centre, MIDC of Mahad M/s ONGC, Ahmedabad (Sites at Jhalora & Kalil) M/s India Oil Corporation Ltd., New Delhi (Site at Panpat, Haryana) M/s Gammon India Ltd. M/s ONGC, Ankleshwar In respect of the above parties, respondent have not paid service tax under Installation and C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee are considered to be services of Erection Commissioning and Installation Servicess. Proposing a demand of Service Tax amounting to Rs. 2,79,72,461 by invoking the extended period of limitation. The said show cause notice was adjudicated vide order-in-original dated 30.10.2013 wherein the adjudicating authority confirmed the demand from 2,79,72,461/- to 1,72,66,282/-. The adjudicating authority accepted the judgment of CCE vs L&T Ltd. 2006 (4) STR 63 but not granted relief to the assessee because at that material time against the above judgment an SLP was filed by the department and relied upon the said order in the case of Enercon India Limited reported in STO 2012 ESTAT 900. Against the said impugned order, the department filed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2021 (44) GSTL 385 (Tri. Mum) ST Electricals Pvt. Ltd. 2019 (20) GSTL 273 (Tri. Mum) CCE vs ST Electricals Pvt Ltd. 2024 (388) ELT 388 (SC) 3. Shri Rajesh Nathan, learned Assistant Commissioner (AR) appearing on behalf of the Revenue reiterates the findings of the impugned order relates to assessee's order to the extent confirmation of demand and he reiterates the grounds of appeal filed by the Revenue. 4. We have carefully considered the submission made by both the sides and perused the records. We find that as per the arguments of Shri Sujit Ghosh, learned Senior Counsel on the basis of various contracts, it is clear that the contracts are on turnkey basis which were executed in lump sum basis and there is no bifurcation of the mat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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