CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL NEW DELHI PRINCIPAL BENCH – COURT NO. III Service Tax Appeal No.51690 of 2021 [Arising out of Order-in-Appeal No.148(CRM) ST/JDR/2021 dated 8.7.2021 passed by the Commissioner (Appeals), Central Excise and CGST, Jodhpur]

Oil India Limited …Appellant

2A, District Shopping Centre, Saraswati Nagar, Basni, Jodhpur, Rajasthan-342005.

Versus Commissioner, CGST, …Responden G-105, New Industrial Area, Opp.Diesel Shed, Basni, Jodhpur, Rajasthan-342 003.

APPEARANCE:

Shri B.L. Narasimhan and Ms. Sukriti Das, Advocates for the appellant Shri Vivek Kumar Jain, Authorised Representative for the respondent CORAM:

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

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

FINAL ORDER NO. 50138/2026 Date of Hearing: 09.01.2026 Date of Decision:21.01. 2026 BINU TAMTA:

1. M/s.Oil India Limited, The Appellant has assailed the Order-in-Appeal No.148(CRM)ST/JDR/2021 dated 08.07.2021, whereby the demand towards service tax on „cash calls‟ have been confirmed under proviso to Section 73(1) of the Finance Act, 1994 along with interest and penalty.

2. The factual matrix of the case submitted by the appellant is as under:-

2.1 The appell