(1.) THE appeal arises from Order -in -Original No. 25/P -III/STC/COMMR/2008 -09, dated 31 -3 -2009 passed by the Commissioner of Central Excise, Pune -III Commissionerate. Vide the impugned order, the ld. Adjudicating authority has confirmed a Service Tax demand of Rs. 6,59,02,514/ - along with interest thereon and also imposed penalties under Section 78 of the Finance Act, 1994 on the appellant, M/s. Balaji Society, Pune by classifying the services rendered by them under 'commercial training or coaching services' during the period 1 -7 -2003 to 31 -3 -2006. Aggrieved of the same, the appellant is before us. The facts relevant to the case are briefly as follows:
(2.) THE ld. Counsel for the appellant made the following submissions.
(3.) WE have carefully considered the submissions made by both the sides. Our findings and conclusions are enumerated in the ensuing paragraphs.