Ms. Jyoti Balasundaram, Vice President - M/s. Indian Oiltanking Ltd. (hereinafter referred to as ‘the assessees’), who are holders of service tax registration for providing three taxable services, viz. (i) storage and warehousing, (ii) port services, and (iii) consulting engineering services, filed a refund claim for Rs. 11,27,498 under the heading "Commissioning and Installation" for the months of September and October 2003 on the ground that lump sum turnkey works contract was entered into by them with M/s. Indian Oil Corporation Ltd., Gujarat Refinery, for constructing storage tank for offsite and utility for LAB project for lump sum contract for entire work of drawing, designing and procurement of materials and construction of storage tank, which could not be split into individual components for levy of service tax. They placed reliance upon Tribunal’s decision in Daelim Industrial Co. Ltd. v. CCE [2007] 7 STT 184 (New Delhi - CESTAT) to support their claim that a lump sum turnkey works contract cannot be vivisected and part of it subjected to tax, which decision was upheld by the Apex Court, and the Tribunal’s decision in Larsen & Toubro Ltd. v. CCE [2005] 1 STT 183 (Ch