CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL NEW DELHI PRINCIPAL BENCH - COURT NO. III SERVICE TAX APPEAL NO.51121 OF 2022 [Arising out of Order-in-Appeal No.337(SM)/ST/JPR/2021 dated 26/28.10.2021 passed by the Commissioner(Appeals), Central Excise &

CGST, Jaipur.]

Om Prakash Garhwal, ….APPELLANT Ward No.24, Behind Tagore Public School, Baswa Road, Bandikui -303 313.

Rajasthan.

VERSUS Commissioner of CGST, A-Block Surya Nagar, …RESPONDENT Alwar, Rajasthan-301 001.

APPEARANCE:

Shri Kumud Bhatnagar, Advocate for the appellant Shri Aejaz Ahmad, Authorised Representative for the respondent CORAM:

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

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

FINAL ORDER NO. 50183 /2026 Date of Hearing:22.01.2026 Date of Decision:30.01.2026 BINU TAMTA:

1. Briefly stated, the appellant is providing ‘work contract services’ for construction of labour sheds, laying damaged roofing with other infrastructure works of construction to the Food Corporation of India, FCI Executive Engineer PWD, Phuleria and Municipal Board, Bandikul. The appellant believed that the services provided by them is exempted from service tax.

2. The Department was of the view that the services