JUDGMENT

Vibhu Bakhru, J.

1. The Revenue has filed the present appeal under Section 35G of the Central Excise Act, 1944 read with Section 83 of the Finance Act, 1994 impugning the final order^{1[Final Oder No.ST/A/51150/2022- in Service Tax Appeal No. 50281/2022 captioned Blackberry India Private Limited v. Commissioner of Central Tax/Excise],} dated 07.12.2022 (hereafter `the impugned order') passed by the Customs, Excise and Service Tax Appellate Tribunal (hereafter `the CESTAT').

2. In terms of the impugned order, the learned CESTAT had allowed the respondent's appeal against an Order-in-Appeal dated 18.08.2021 passed by the Commissioner (Appeals) rejecting the respondent's appeal against an Order-in-Original dated 31.08.2020 passed by the Adjudicating Authority.

3. By the said Order-in-Original dated 31.08.2020, the Adjudicating Authority had rejected the respondent's claim for refund of Rs.8,55,34,345/- on account of unutilised CENVAT Credit for three mentioned periods, that is, (i) April to June 2012; (ii) April to June 2013, and (iii) July 2013 to September 2013.

4. The respondent (hereafter `BlackBerry India') was registered with the Department for payment of service tax i