CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL MUMBAI REGIONAL BENCH - COURT NO. I SERVICE TAX APPEAL No. 87082 of 2022 [Arising out of Order-in-Appeal No. DL/63-64/APPEALS THANE/BW/2022-23 dated 23.06.2022 passed by the Commissioner of CGST & Central Excise (Appeals), Thane, Mumbai.]

Nirmangold Property Developers Pvt. Limited .… Appellants C/o Nitin Anant Patil, Owala Mogharpada, Ghodbunder Road Thane, Maharashtra – 400 615.

VERSUS Commissioner of CGST & Central Excise …. Respondent Bhiwandi Commissionerate

12th Floor, Lotus Info Centre, Station Road, Parel (East)

Mumbai – 400 012.

Appearance:

Shri Vinod Awtani, Chartered Accountant for the Appellants Shri S.B.P. Sinha, Authorized Representative for the Respondent CORAM: HON’BLE MR. M.M. PARTHIBAN, MEMBER (TECHNICAL)

FINAL ORDER NO. A/85028/2026 Date of Hearing: 28.11.2025 Date of Decision: 20.01.2026 PER: M.M. PARTHIBAN This appeal has been filed by M/s. Nirmangold Property Developers Private Limited, Thane (herein after, for short, referred to as ‘the appellants’) against the Order-in-Appeal No. DL/63-64/ APPEALS THANE/BW/2022-23 dated 23.06.2022 (referred to, as ‘the impugned order’) passed by the Commissioner of CGST & Central Exc