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2026 Supreme(Online)(CESTAT) 328

CUSTOMS EXCISE & SERVICE TAX APPELLATE TRIBUNAL
P. Dinesha, J, Vasa Seshagiri Rao, Technical Member
M/s. City Union Bank Ltd. – Appellant
Versus
Commissioner of GST and Central Excise – Respondent


Advocates:
For the Appellants: Mr. S. Ananthan, Chartered Accountant
For the Respondent: Ms. Anandalakshmi Ganeshram, Authorised Representative

Table of Content
1. overview of facts related to service tax appeals. (Para 1 , 2 , 3)
2. arguments and positions of the appellants and the department. (Para 4 , 5 , 9)
3. court's examination of statutory provisions and evidence. (Para 7)
4. key legal questions arising from the appeals. (Para 8)

Per Mr. VASA SESHAGIRI RAO

The Appellants, M/s. City Union Bank Limited (CUB) and M/s. Karur Vysya Bank Limited (KVB), are scheduled banking companies engaged in providing Banking and Other Financial Services to customers across India. Both Banks were holding centralised Service Tax registrations during the relevant periods and were regularly filing ST-3 returns, discharging service tax wherever applicable, and availing CENVAT credit in accordance with the law.

1.2 Both the Banks were subjected to periodic departmental audits, and their books of accounts and statutory records were made available to the Department during the course of such audits.

2. The period involved in the appeal filed by City Union Bank Limited is 01.04.2014 to 30.06.2017.

2.1 During verification of the financial records of the Bank, the Department noticed the following: -

i. the Bank had collected penal interest from borrowers o

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