CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL NEW DELHI PRINCIPAL BENCH – COURT NO. III SERVICE TAX APPEAL NO. 50539 OF 2022 [Arising out of Order-in-Appeal No.346(SM)ST/JPR/2021 dated 08.11.2021/09.11.2021 passed by the Commissioner(Appeals) Central Excise and Central GST, Jaipur ]

M/s Mitsui Prime Advanced Composites India Pvt Ltd …Appellant SP2-54-55-56, Complex Industrial Area,Majarkath, Neemrana, Alwar, Rajasthan-301 705 Versus Commissioner(Appeals), Central Excise & CGST, Jaipur …Respondent NCRB, Statue Circle, Jaipur-302 005 APPEARANCE:

Shri Shashank Shekhar, Advocate for the appellant Shri S.K. Meena, Authorised Representative for the respondent CORAM:

HON’BLE MS. BINU TAMTA, MEMBER (JUDICIAL)

HON’BLE MS. HEMAMBIKA R. PRIYA, MEMBER (TECHNICAL)

FINAL ORDER NO.50085/2026 Date of Hearing: 16.01.2026 Date of Decision: 20.01.2026 BINU TAMTA:

1. By the impugned order, Order in Appeal No. 346(SM)/ST/JPR/2021 dated, the Commissioner (Appeals) confirmed the liability to pay service tax on ‘Ocean Freight’ under reverse charge along with interest and penalty.

08.11.2021/09.11.2021

2. The appellant is primarily engaged in the manufacture of Polypropylene Compound falling under sub heading 3