CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL MUMBAI WEST ZONAL BENCH SERVICE TAX APPEAL NO: 85971 OF 2015 [Arising out of Order-in-Original No: GOA-EXCUS-000-COM-018-2014-15 dated

30^th January 2015 passed by the Commissioner of Customs & Service Tax, Goa.]

Wilson Godinho Wides Properties & Holdings F-2 3rd Floor Narvekar Trade Centre Opp: Azad Maaidan M G Road Panaji Goa - 403 001 … Appellant versus Commissioner of Central Excise & Service Tax IDC House, EDC Complex, Patto Plaza, Panaji Goa – 403001 …Respondent APPEARANCE:

Shri BJ Raichandani, Advocate and Ms Neha Chakraborty, Advocate for the appellant Shri Priyesh Bheda, Joint Commissioner (AR) for the respondent CORAM:

HON’BLE MR C J MATHEW, MEMBER (TECHNICAL) HON’BLE MR AJAY SHARMA, MEMBER (JUDICIAL)

FINAL ORDER NO: 85114 /2026 DATE OF HEARING: 28/10/2025 DATE OF DECISION: 23/01/2026 PER: C J MATHEW M/s Wilson Godinho deals in properties. He acquires real estate from land owners and contracts with intending purchasers of these properties. He has no title to the properties but is in possession consequent upon agreement with the owners of the properties. Alleging that this activity was tantamount to rendering ‘real estate agent