CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL MUMBAI WEST ZONAL BENCH, MUMBAI Service Tax Appeal No. 86399 of 2017 [Arising out of Order-in-Appeal No. PK/ST-I/MUM/192/2016-17 dated 24.03.2017 passed by the Commissioner of Service Tax (Appeals)-I, Mumbai.]

M/s. Uniphos International Limited ........Appellant (Formerly known as “Uniphos Agro Industries Ltd.”)

4^th Floor, Readymoney Terrace, 167, Dr. AB Road, Worli, Mumbai – 400 018 VERSUS Commissioner of CGST, Mumbai Central ........Respondent

10^th Floor, Lotus Infotech Building, Near Parel Station, Mumbai – 400 012 APPERANCE Shri Kshitij Kasi, Advocate for the Appellant Shri S.B.P. Sinha, Superintendent, Authorised Representative for the Respondent CORAM:

HON’BLE DR. SUVENDU KUMAR PATI, MEMBER (JUDICIAL)

FINAL ORDER NO. 85020/2026 Date of Hearing: 07.01.2026 Date of Decision: 07.01.2026 This appeal has been filed against rejection of refund order passed by the Commissioner (Appeals) at the instance of the Respondent herein for an amount of ₹68,453/- sanctioned earlier by the Refund Sanctioning Authority to the Assessee.

2. Before argument is led by the parties, learned Authorised Representative Mr. Sinha raised a point that value of app