CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL New Delhi PRINCIPAL BENCH – COURT NO. 3 [Arising out of Order-in-Appeal No. 86-ST/2019 dated 01.04.2021 passed by the Principal Commissioner (Appeals) of CGST and Central Excise, Delhi]

Supercity Infratech Private Limited : Appellant Sl. Defence Enclave Vikas Marg, New Delhi-110092 Vs Commissioner of Central Excise and : Respondent CGST-Delhi East Room No. 134, Central Revenue Building I.P. Estate, East Delhi New Delhi APPEARANCE:

Shri A.K. Prasad and Ms. Surabhi Sinha, Advocates for the appellant Shri Rakesh Kumar, Authorised Representative for the respondent CORAM :

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

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

FINAL ORDER No. 50342/2026 Date of Hearing:02.02.2026 Date of Decision:12.03.2026 HEMAMBIKA R. PRIYA The present appeal has been filed by Supercity Infratech Private Limited¹ to assail the Order-in-Appeal No. 86-ST/2019 dated 01.04.2021 wherein the Commissioner rejected the appeal on the grounds of limitation.

2. The brief facts of the case are that the appellant was a provider of "Construction of Residential Complex services. Following the receipt of intelligence of non-payment of Se