IN THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL EASTERN ZONAL BENCH : KOLKATA REGIONAL BENCH – COURT NO. 1 Service Tax Appeal No. 77022 of 2016 (Arising out of Order-in-Original No. 45-46/S.Tax/Commr/2016 dated 28.03.2016 (issued on 31.03.2016) passed by the Commissioner of Central Excise & Service Tax, 5-A, Main Road, Ranchi – 834 001)

M/s. Vedika Credit Capital Limited : Appellant

406, Shrilok Complex, 4^th Floor, H.B. Road, R anchi – 834 001 VERSUS Commissioner of Central Excise and Service Tax : Respondent Ranchi-I Commissionerate, 5-A, Main Road, Ranchi – 834 001 APPEARANCE:

Shri Arun Kumar Agarwal, Chartered Accountant, Shri Ranjeet Garodia, Chartered Accountant, Shri Rohit Kumar Agarwal, Chartered Accountant, For the Appellant Shri Prasenjit Das, Authorized Representative, For the Respondent CORAM:

HON’BLE SHRI ASHOK JINDAL, MEMBER (JUDICIAL)

HON’BLE SHRI K. ANPAZHAKAN, MEMBER (TECHNICAL)

FINAL ORDER NO. 76541 / 2025 DATE OF HEARING: 04.06.2025 DATE OF DECISION: 18.06.2025 ORDER: [PER SHRI K. ANPAZHAKAN]

M/s. Vedika Credit Capital Limited (hereinafter referred as to as the “appellant”) is a non-banking finance company (‘NBFC’) engaged in the business of providing personal loans, two-wheeler loans, and microfinance loans to their customers. The appellant earns interest income through the provision of such loans. Additionally, for facilitating such loans, various charges are being collected from their customers depending upon the nature of loan given.

2. Proceedings were initiated against the appellant by way of issuance of two Show Cause Notice Notices dated 04.12.2014 and 02.03.2015, wherein the following demands have been raised:

2.1. The said Notices were adjudicated by a common order dated 28.03.2016 (issued on 31.03.2016), wherein the Ld. adjudicating authority has passed the following order:

“(i) I confirm the demand of total service tax amounting to Rs.1,48,28,953.00 (Rs. One crore Forty eight lakh Twenty eight thousand Nine hundred Fifty three only) (including Education Cess and S. H. Ed. Cess not paid/short paid for the period from 01.10.2007 to 31.12.2012 involved in the Show Cause Notice C. No. V (30) 143/Prev/VCCL/Ran (H)/T-2/2014/18277-82 dated 04.12.2014 under Section 73 (2) of Chapter V of the Finance Act, 1994 read with Section 111 of the Finance Act, 2013 and the same is ordered for recovery from the said noticee no. 1;

(ii) I appropriate the Service Tax amount of Rs. 10,40,076.00 already deposited by the said noticee no. I under VCES, 2013 against the demand confirmed at Sl. No (i) hereinabove;

(iii) I confirm the demand of interest on the demand confirmed at Sl. No. (i) hereinabove and order for its recovery from the said noticee no. I under the provisions of Section 75 of the Finance Act, 1994 read with section 111 of the Finance Act, 2013;

(iv) I impose a penalty of Rs. 1,48,28,953.00 (Rs. One crore Forty eight lakh Twenty eight thousand Nine hundred Fifty three only) on the said noticee no. I under the provisions of Section 78 of the Finance Act, 1994 read with Section 78B of the Finance Act, 1994 and section 111 of the Finance Act, 2013. If Service Tax and interest determined at Sl. No. (i) and (m) hereinabove is paid within a period of thirty days of the date of receipt of this order the penalty shall be twenty five per cent of the penalty imposed, provided if such reduced penalty is also paid within the aforementioned period;

(v) I impose a penalty of Rs 10,000/- on the said noticee no. I under the provisions of Section 77 of the Finance Act, 1994 read with section 111 of the Finance Act, 2013 for contravention of various provisions of Finance Act, 1994 as discussed hereinabove;

(vi) I impose personal penalty of Rs. 1,00,000/- (Rs. One lakh only) upon Shree Gautam Jain, Director of the said noticee no. 1 under section 78 A of the Finance Act, 1994 as much as he deliberately failed to make correct declaration under VCES, 2013 with intent to evade Service Tax;

(vii) I confirm the demand of Service Tax am