JUDGMENT :

Milind N. Jadhav, J.

1. Heard Mr. Vijay Kantharia along with Mr. D.B. Deshmukh, Advocates for the appellant and Ms. Padmavati Patil along with Mr. Kiran Chavan, Advocates for the respondent.

2. This appeal has been filed by the Commissioner of Central Goods and Services Tax under the provisions of Section 35G of the Central Excise Act, 1994 (briefly referred to as "the said Act") to challenge the order No. A/86601/2018 dated 29.05.2018 passed by the Customs, Excise, & Service Tax Appellate Tribunal (briefly referred to as "the CESTAT"), West Zonal Bench, Mumbai in Appeal No. ST/86027/14 arising out of Order-in-Original No. 119-121/STC-1/SKS/13-14 dated 24.12.2013 passed by the Commissioner of Service Tax, Mumbai - I.

3. The appellant has preferred the appeal on the following substantial questions of law:

“a. Whether the Hon’ble Tribunal was correct in holding that the activity is not taxable prior to 01.03.2006 as there was no mechanism provided for bifurcation of value of service from the interest amount?

b. Whether the Hon’ble Tribunal was correct in holding that the period prior to 01.03.2006 is not taxable in the absence of mechanism for bifurcation of Service Income as p