SANJIV SRIVASTAVA:

This appeal is directed against Order-in-Appeal No. GZB/EXCUS/000/APPL/ MRT/01/2025-26 dated 04.04.2025 of the Principal Commissioner, CGST (Appeals), Meerut. By the impugned order following has been held:

8. In light of the cited facts and findings taken into consideration in their entirety, I find that the subject appeal does not hold factual and statutory grounds w.r.t. the demand of Rs 7,85,949/- (14,80,387 - 6,94,438). Relatedly, on the basis of foregoing facts and findings, I hereby modify the impugned order on merits as under;

(i) I Confirm the demand of Service Tax, amounting to Rs. 7,85,949/- for the period 2014-15 by invoking the first proviso to Section 73 (1) of the Finance Act , 1994 read with Section 174 of the CGST Act, 2017 and appropriate amount of Rs. 6,94,438/- already deposited by the appellant against the confirmed demand of Rs, 14,80,387/- vide OIO dated 24.04.2024 and not in relation to the demand of Rs. 7,85,949/- confirmed under this para.

(ii) I Confirm the demand of Interest on the above amount of Service Tax Rs. 7,85,949/- under Section 75 of the Finance Act , 1994 read with section 174 of the CGST Act, 2017.

(iii) I Impose a Penalty of