TATA MOTORS LTD. Vs. COMMISSIONER OF CGST

JUDGEMENT

(1.) These are two appeals which arise from a common order dtd. 8/1/2019 passed by the Customs, Excise & Service Tax Appellate Tribunal (for short "Tribunal"). Insofar as Central Excise Appeal No.1 of 2021 is concerned, challenges an order in Appeal (St.) No.86329 of 2016 in which relevant period in respect of the show cause notice is April 2013 to March 2014. Insofar as Central Excise Appeal No.4 of 2021 is concerned, the challenge to an order in Appeal (St.) No.86215 of 2015 in which relevant period for which the show cause notice issued to the Appellant is 2011-12 & 2012-13.

(2.) The Appellants have filed appeals before the Tribunal against the Order-in-Original passed by the Commissioner, Service Tax, Mumbai-II by which the Commissioner had adjudicated the show cause notices issued to the appellants the details of which are set out in paragraph 1.1 of the impugned order. The Commissioner had adjudicated the show cause notices and confirmed the duty demand along with interest in respect of Authroised Service Station Services, Banking and Other Financial Services of the Appellant and also penalty under Sec. 76 of the Finance Act, 1994 was imposed.

(3.) We need not advert to the facts in detail, suffice it to observe that in the present appeals the Appellant has raised the following substantial questions of law : -