JUDGMENT :

Dhananjaya Y. Chandrachud, J.

This appeal arises from a judgment and order of the Customs, Excise, & Service Tax Appellate Tribunal,¹["Tribunal"] West Zonal Bench at Ahmedabad in Service dated 5 April 2019. The Tribunal has, in exercise of its appellate jurisdiction, reversed the 30 March 2011 decision of the Commissioner of Service Tax, Ahmedabad ²["Adjudicating Authority"] and set aside the demand for payment of service tax on the charges collected by the respondent for supply of pipes and measuring equipment to its customers under Section 65(105)(zzzzj) of the Finance Act, 1994. This appeal rests on the interpretation and applicability of the provisions of Section 65(105)(zzzzj) of the Finance Act, 1994.

2. The respondent is in the business of distributing natural gas - Compressed Natural Gas³ ["CNG"] and Piped Natural Gas⁴ ["PNG"] - to industrial, commercial, and domestic consumers. Among other purposes, industrial consumers use PNG for manufacturing operations. Domestic and commercial consumers use PNG for cooking, power supply and air-conditioning. In order to fac