CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL, MUMBAI REGIONAL BENCH - COURT NO. I Service Tax Miscellaneous Application No. 87278 of 2025 (on behalf of the appellant)

In Service Tax Appeal No. 86019 of 2018 AND Service Tax Appeal No. 86019 of 2018 (Arising out of Order-in-Appeal No. PUN-EXCUS-001-1PP-882/2017-18 dated

14.12.2017 passed by the Commissioner of Central Tax (Appeals-I), Pune)

M/s Bosch Chassis Systems India Pvt. Ltd. .… Appellant Gat No. 306, Nanekarwadi, Chakan, Khed, Pune – 410 501 Versus Principal Commissioner of Central Goods & …. Respondent Service Tax, Pune-I

41/A, 2^nd Floor, GST Bhavan, Sassoon Road, Opp. Wadia College, Pune – 411 001 APPEARANCE:

Shri Jay Chheda a/w Shri Prithish, Advocates for the Appellant Shri C.S. Pavan, Authorized Representative for the Respondent CORAM:

HON’BLE MR. S.K. MOHANTY, MEMBER (JUDICIAL)

HON’BLE MR. M.M. PARTHIBAN, MEMBER (TECHNICAL)

FINAL ORDER NO. A/85157/2026 Date of Hearing: 19.01.2026 Date of Decision: 19.01.2026 PER: S.K. MOHANTY Heard both sides and examined the case records.

2. Appellant has filed this miscellaneous application seeking for change of name and address of the respondent arising on account of change in territorial jurisdiction of the Central Excise authorities after introduction of GST regime vide Notification No.13/2017-C.E. (N.T) dated 09.06.2017 and as the appellants-assessee presently comes under their jurisdiction. As the revised name and address of the respondent Commissionerate correctly reflect the revised jurisdictional departmental authorities, under whose jurisdiction the appellants-assessee is functioning for the purpose of indirect taxes viz., Central Excise/GST, the miscellaneous application filed by the appellant is allowed. The prayer made by the appellant is considered and the revised name and address of the respondent is duly incorporated for the purpose of disposal of the appeals. Registry is directed to incorporate the following changed name and address of the respondent in the appeal records for the purpose of office records.

“Principal Commissioner, Central Goods and Services Tax (CGST), Pune-I Commissionerate, 2nd Floor, GST Bhavan, Sassoon Road, Opp. Wadia College Pune – 411 001.”.

3. Brief facts of the case are that the appellants are engaged, inter alia, in the manufacture of Motor Vehicle Brake Parts, falling under Tariff Item 8708 3000 of the First Schedule to the Central Excise Tariff Act, 1985. The appellants purchased various materials required for their manufacturing operation from various suppliers/vendors. As per the prevailing trade and industry practice, the vendors offered cash discounts to the appellants for making prompt/early payments before the stipulated date provided in the agreement. The cash discounts so provided by the vendors are deducted from the invoice amount and the net amount was paid by the appellants towards the cost of materials supplied by the vendors. However, the offer of discount availed by the appellants was interpreted by the Department as rendering of financial services towards ‘bill/cash discounting’ and accordingly, should be categorized as a taxable service under the taxing head of “Banking and other Financial Services”. The show-cause notice dated 25.02.2016 issued in this regard was adjudicated vide the Order-in- Original dated 23.03.2017, wherein the original authority had confirmed the proposals made in the show-cause notice. On appeal against the said adjudication order dated 23.03.2017, the learned Commissioner (Appeals) vide the impugned order No. PUN-EXCUS-001-1PP-882/2017-18 dated 14.12.2017 has dropped the demand confirmed for the period 01.07.2012 to 31.03.2015, holding that under the new Service Tax regime, the service falling under the negative list as per Section 66D of the Finance Act, 1994, would not be subjected to payment of service tax. However, for the prior period, he has upheld confirmation of the adjudged demand in line with the observations made in the original order. Feel