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2026 Supreme(Online)(CESTAT) 195

CUSTOMS EXCISE & SERVICE TAX APPELLATE TRIBUNAL
Sanjiv Srivastava, Technical Member
M/s SRJ EDU Services Pvt. Ltd. – Appellant
Versus
Commissioner of Central Goods & Services Tax, Ghaziabad – Respondent


Advocates:
For the Appellants/Petitioners: Shri R.S. Sharma
For the Respondents: Ms Chitra Srivastava

SANJIV SRIVASTAVA:

This appeal is directed against Order-in-Appeal No.GZB/EXCUS/000/APPL/MRT/12/2025-26 dated 30/06/2025. passed by Commissioner (Appeals) CGST, Meerut By the impugned order following has been held:-

“ORDER

In the light of the discussion and findings recorded above, I set aside the Impugned Order-In-Original No. 35/GST/AC/D-III/GZB/T.P.S.Tax/2024-25 dated 10.07.2024 and allow the present appeal bearing No. No.79-ST/APPL-MRT/GZB/2024-25 dated 27.11.2024 filed by the Commissioner, Central GST Commissionerate, Ghaziabad through the Assistant Commissioner, Central GST, Division-III, Ghaziabad partially by way of remand to the adjudicating authority as discussed supra.”

2.1 Appellant is registered with the Service Tax Department for providing taxable services as defined under Section 65B (44) of the Finance Act, 1994 . They hold three registration nos. as detailed below:-

 Registration No.AAACR6837PSD005

 Registration No.AAACR6837PSD001

 Registration No.AAACR6837PSD003

2.2 On the basis of third party information received from the Income Tax Department for the financial year 2016-17, it was observed that appellant has declared amounts to the income tax which do not tally with

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