Siri Jagan, J.

The issues involved in these two appeals are identical. Therefore the two appeals are disposed of by this common judgment.

2. The matter relates to payment of service tax, interest and penalty under the Finance Act, 1994, by the respondent in each of the two appeals. The Revenue is the appellant in both the appeals. Notices were issued to the respondents in these two appeals directing them to show cause why service tax amounting to Rs.27,425/= and Rs.33,450/=, respectively along with interest as applicable under Section 75, as also penalty under Sections 76 and 78 of the Finance Act, 1994, should not be recovered from them for failure to pay service tax and suppression of the value of taxable service with intent to evade payment of service tax. The show cause notices culminated in demand for service tax, interest and penalty under both Sections 76 and 78 of the Finance Act, 1984. The respondents in these appeals challenged the same in appeals before the Commissioner of Central Excise (Appeals). However, the appeals were dismissed since the same were filed beyond the period prescribed under sub section 3 of Section 85 of the Finance Act, 1984 and the Commiss