IN THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL EASTERN ZONAL BENCH: KOLKATA REGIONAL BENCH – COURT NO. 1 Service Tax Appeal No. 75939 of 2021 (Arising out of Order-in-Original No. PR.COMMR/BBSR/ST/30/2021 dated 13.09.2021 passed by the Principal Commissioner, C.G.S.T. & Central Excise, Bhubaneshwar, C.R. Building, Rajaswa Vihar, Bhubaneswar – 751 007, Odisha)

M/s. NESCO Utility : Appellant A.T./P.O.: Januganj, Balasore, Odisha – 756 019 VERSUS Principal Commissioner, G.S.T. and C.Ex., : Respondent Bhubaneswar Commissionerate, C.R. Building, Rajaswa Vihar, Bhubaneswar, Odisha – 751 007 APPEARANCE:

Shri Niranjan Swain, Advocate, For the Appellant Ms. Suman, Authorized Representative, for the Respondent CORAM:

HON’BLE SHRI ASHOK JINDAL, MEMBER (JUDICIAL)

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

FINAL ORDER NO. 75284 / 2026 DATE OF HEARING / DECISION: 24.02.2026 ORDER: [PER SHRI ASHOK JINDAL The appellant is in appeal against the impugned order wherein the demand of central excise duty amounting to Rs.25,33,67,733/- (inclusive of cess), along with interest and penalties thereon, has been confirmed against the appellant.

2. The facts of the case are that M/s. NESCO Utility (a