CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL NEW DELHI PRINCIPAL BENCH-COURT NO. 1 SERVICE TAX APPEAL NO. 50259 OF 2021 [Arising Out Of Order In Original No. 12/2020-St Dated 15.06.2020 Passed By The Additional Director General (Adjudication), New Delhi]

LI & FUNG INDIA PRIVATE LIMITED …….APPELLANT Tower-B, S.P. Infocity, 243, Udyog Vihar Phase I, Gurugram, Haryana-122016 Vs.

COMMISSIONER, CGST-DELHI ……RESPONDENT Appearance:

Shri Tarun Gulati, Senior Advocate, Shri Deepak Suneja, Chartered Accountant, Shri Jayant Sharma and Shri Kumar Sambhav, Advocates for the Appellant Shri C. Dhanshekharan, Special Counsel for the Respondent CORAM:

HON'BLE MR. JUSTICE DILIP GUPTA, PRESIDENT HON'BLE MR. P.V.SUBBA RAO, MEMBER ( TECHNICAL )

FINAL ORDER NO. 50625 /2026 DATE OF HEARING : 11/02/2026 DATE OF DECISION : 27/03/2026 P.V. SUBBA RAO

1. M/s Li & Fung, India Private Limited¹ filed this appeal to assail the order dated 15.06.2020² passed by the Additional Director General³, Director General of GST Intelligence⁴ in which he decided the proposals made in the Show Cause Notice dated

1 Appellant

2 Impugned order

3 ADG

4 DGGST

11.10.2018⁵ issued to the appellant by the ADG covering the period from October