PER: M.M. PARTHIBAN

This appeal has been filed by Mrs. Varkha Deepak Melwani, Mumbai (herein after, for short, referred to as ‘the appellant’) against the Order-in-Appeal No. SK/CGST/A-I/Mum/301/23-24 dated 14.11.2023 (referred to, as ‘the impugned order’) passed by the Commissioner of CGST & Central Excise (Appeals-I), Mumbai.

2.1 Brief facts of the case, leading to this appeal, are summarized herein below:

2.2 The appellant herein, inter alia, is engaged in providing “Renting of immovable property service” and for the purpose of payment of service tax and for compliance with service tax statute are registered with jurisdictional authorities holding Service Tax Registration No. AAHPM3360QST001. They are also holding PAN No. AAHPM3360Q for the purpose of income tax purpose. The appellant was also erroneously allotted by the departmental AIO portal one another Service Tax Registration being No. AAHPM3360QST002, which was not operational.

2.3 During the course of verification of ST-3 Return data filed by the appellant with the data regarding declared turnover in Income Tax Return (ITR)/Tax Deducted at Source (TDS) through 26AS for the year 2015-16, the department had come to a conclusio