JUDGMENT :

(Krishna Rao, J.) :

1. The petitioner has filed the present writ application challenging the letter dated August 7, 2020, letter dated September 16, 2020 and the Order dated March 6, 2018 issued by Superintendent, CGST and Central Excise, Range III, Siliguri Division imposing penalty of Rs. 7,58,764/-upon the petitioner under Section 78 of the Finance Act, 1994.

2. The petitioner is engaged in the service of providing vehicle on hire on a monthly basis with the respondent no. 5 i.e. the Siliguri Jalpaiguri Development Authority as on required basis since the year 2009 and also started providing vehicle to respondent no. 4 being North Bengal Development Department since the year 2012.

3. The Assistant Commissioner, Head Quarter, Anti-Evasion Unit for the first time on August 11, 2015 issued a letter to the petitioner for verification of Service Tax liability under the Finance Act, 1994 and requested the petitioner to submit necessary documents within seven days from the date of receipt of the letter.

4. On receipt of the said letter, the petitioner came to know that the service relating to “Rent-a-Cab” is also taxable service and required to be registered before the said