CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL NEW DELHI PRINCIPAL BENCH - COURT NO. II SERVICE TAX APPEAL NO. 51730 OF 2022 [Arising out of Order-in-Original No.22-23/2021-ST Dated 17.11.2021 passed by the Additional Director General(Adjudication), Delhi]

M/s NAVAL GROUP INSURANCE FUND ….APPELLANT Room No.124, Wing-A, Sena Bhawan, Integrated Headquarters,(NAVY), Ministry of Defence, Kamraj Road, New Delhi-110 001 VERSUS ADDITIONAL DIRECTOR GENERAL …RESPONDENT Director General of GST Intelligence (Adjudication Cell), West Block-VIII, Wing-6, 2^nd Floor, R.K. Puram, New Delhi APPEARANCE:

Shri A.K Batra, Advocate for the appellant Shri Rohit Issar, Authorised Representative for the respondent CORAM:

HON’BLE MR. ASHOK JINDAL, MEMBER (JUDICIAL)

FINAL ORDER NO.50618/2026 Date of Hearing/Decision: 24.03.2026 ASHOK JINDAL:

1. Both the appeals are involve a common issue are being disposed of by a common order.

2. The facts of the case are that the appellant is a registered society under the Societies Registration Act, 1860, with Navy Coast, and its members. The appellant provides various services to its members but did not charge any Service Tax on such services. The Revenue was of the view th