CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL ALLAHABAD REGIONAL BENCH - COURT NO.I (Arising out of Order-In-Appeal No. 335-ST-APPL-LKO-2025, dated - 29/09/2025 passed by Commissioner (Appeals) CGST & Central Excise, Lucknow)

M/s Shailja Construction …..Appellant (Bank Colony, New Abadi Premier Nagar, Aligarh, Uttar Pradesh 202001)

VERSUS Commissioner, CGST & Central Excise, Agra ….Respondent (113/4 Sanjay Place, Agra, Uttar Pradesh 282002)

APPEARANCE Shri Raj Kumar, F.C.A. for the Appellant Smt. Chitra Srivastava, Authorized Representative for the Respondent CORAM: HON’BLE MR. P.K. CHOUDHARY, MEMBER (JUDICIAL)

FINAL ORDER NO.-70044/2026 DATE OF HEARING : 12.02.2026 DATE OF DECISION : 20.02.2026 P. K. CHOUDHARY:

The present appeal has been filed by the Appellant assailing the Order-In-Appeal No. 335-ST-APPL-LKO-2025, dated -29/09/2025 passed by Commissioner (Appeals), Customs, CGST & Central Excise, Lucknow.

2. Briefly stated, the facts of the case are that the Appellant M/s Shailja Construction is a partnership concern engaged in providing construction services of Road and Canal to Government and Local Authorities.

3. The Appellant were under a bona fide belief that the services provi