ORDER:

[PER SHRI K. ANPAZHAKAN]

The present appeal has been filed challenging the Order-in-Original No. 60/COMM/ST/SLG/23-24 dated 28.03.2024 passed by the Commissioner, Siliguri Central Excise and C.G.S.T. Commissionerate wherein the demand of Service Tax amounting to Rs.2,86,48,709/- (inclusive of cesses) for the period from April 2015 to March 2017 has been confirmed, along with interest. A penalty equal to the above Service Tax demand confirmed has also been imposed by the ld. adjudicating authority under Section 78 of the Finance Act, 1994 ; penalty of Rs.10,000/- under Section 77 (1)(c) of the Act and late fee of Rs.80,000/- on account of non-filing of ST-3 Returns under Section 70 of the Act read with Rule 7(C) of the Service Tax Rules, 1994 have also been imposed.

2. The facts of the case are that M/s. Nanu Shome & Co. (hereinafter referred to as the “appellant”), is a firm engaged in the business of providing works contract services relating to construction of civil structures, construction of road, river embankment, canal for irrigation related works, etc., to various local authorities and government bodies. The appellant- firm had Mr. Sandeep Shome and Mrs. Nanu Shome as