JUDGMENT :

ABHAY AHUJA, J.

1. The Petitioner, a Company incorporated as APL (India) Pvt. Ltd. under the Companies Act, 2013 which entity vide order dated 15 November 2017 of the National Company Law Tribunal, merged with CMACGM Agencies (India) Pvt. Ltd., is engaged inter-alia in the business of providing services under the category of Steamer Agent service, Cargo Handling service, Business Support Service, GTA and Business Auxiliary service and has offices across India for providing the said services.

2. It is the case of the Petitioner that during the relevant period, various offices of the Petitioner were holding separate service tax registrations with their respective jurisdictional Commissionerate; accordingly, the Delhi office of the Petitioner was holding Service Tax Registration No.AABCA2731NST002 under the jurisdiction of Range-12, Service Tax Division-II, Service Tax Commissionerate, New Delhi.

3. Pursuant to an audit conducted for the period 2004-05 to 2007-08, the Delhi office of the Petitioner was issued a Show Cause cum Demand Notice No.59 of 2009 dated 12 October 2009 (the “show cause cum demand notice”) by the Commissioner of Service Tax, Delhi, calling upon the Petitio