JUDGMENT

Dharmesh Sharma, J. The petitioner is invoking the writ jurisdiction of this Court second time under Article 226 & 227 of the Constitution of India. The petitioner is a company incorporated under the provisions of Companies Act, 1956 and engaged in the business of providing hardware support and services in the areas of broadcasting and telecommunication, both terrestrial and satellite, which primarily includes supplying the broadcast equipment, catering to required system integration for the same and other aspects of incidental design, consultancy and support services.

GENESIS-FIRST ROUND OF DISPUTE

2. Briefly stated, the petitioner was assessed to service tax inter-alia in relation to commission income received from outside India and vide order dated 14.06.2019 passed by respondent no.3/Commissioner (Appeal), Central Tax GST, Delhi-1. The petitioner was imposed a total demand of Rs.1,00,89,786/- along with interest and penalty of Rs.1,00,89,786/-. Needless to state the petitioner had a statutory right to file appeal within a period of two months from the date of receipt of the order (received on 19.06.2019) under Section 85(3A) of the Finance Act, 1994 ("the Act") which wa