JUDGMENT :

M.R. Shah, J.

1. Feeling aggrieved and dissatisfied with the impugned common judgment and order passed by the Customs, Excise and Service Tax Appellate Tribunal, Ahmedabad passed in orders in Appeal Nos. 3085 to 3087 of 2007 by which the learned Tribunal has allowed the said appeals preferred by the respondent assessee (by a majority) and set aside the demand of duty and penalty as per the Revisional Authority’s order, the Revenue has preferred the present appeals.

2. The dispute is with respect to the period July, 1997 to December, 2000. A show cause notice dated 04.06.2001 was issued against the respondent – assessee, proposing demand of duty (service tax demand) of Rs.1,84,75,749/and proposing the imposition of penalty on the grounds, inter alia, that the assessee is providing the services to its customers as consulting engineer and therefore liable to pay the service tax.

2.1 At this stage, it is required to be noted that the respondent assessee company was engaged in the manufacture of mechanical, engineering and electrical goods falling under Chapters 84 and 85 of Central Excise Tariff Act, 1985. In respect of certain buyers, the assessee merely sold their products