IN THE CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL, CHENNAI Service Tax Miscellaneous Application No. 40057 of 2025 in Service Tax Appeal No. 40911 of 2015 (Arising out of Order in Appeal No. 47/2015 (STAX – II) dated 10.02.2015 passed by the Commissioner of Service Tax (Appeals – II), Chennai)

And Service Tax Appeal Nos. 41709 to 41712 of 2016 (Arising out of Order in Appeal No. 68 to 71/2016 (STAX – II) dated 13.06.2016 passed by the Commissioner of Service Tax (Appeals – II), Chennai)

LV Prasad Film & TV Academy Appellant ( A unit of Prasad Productions Pvt. Ltd.)

28, Arunachalam Road, Saligramam Chennai – 600 035.

Vs.

Commissioner of GST & Central Excise Respondent Chennai South Commissionerate MHU Complex, Nandanam, Chennai – 600 035. APPEARANCE:

Shri Raghavan Ramabhadran, Advocate for the Appellant Smt. Anandalakshmi Ganeshram, Authorised Representative for the Respondent CORAM Hon’ble Shri M. Ajit Kumar, Member (Technical)

Hon’ble Shri Ajayan T.V., Member (Judicial)

FINAL ORDER NOS. 40514-40518/2026 Date of Hearing: 23.12.2025 Date of Decision: 22.04.2026 Per M. Ajit Kumar, These appeals challenge Order-in-Appeal No. 47/2015 (STAX-II)

dated 10.02.2015 and Order-in-Appeal Nos. 68 to 71/2016 (STAX-II) dated 13.06.2016 passed by the Commissioner of Service Tax (Appeals-II), Chennai (impugned orders).

2. The Appellant provides training and coaching in direction, cinema photography, and film processing and collects course fees. It appeared that the Appellant neither registered with the Department nor paid Service Tax on the fees collected. Accordingly, three Show Cause Notices (SCN), dated 08.09.2009, 12.09.2009, and 27.09.2010 were issued for the period 2005-06 to 2009-10, proposing levy of Service Tax under the category of ‘Commercial Training or Coaching Service.’ The Adjudicating Authority confirmed demands along with interest and penalties under Sections 76, 77, and 78 of the Finance Act, 1994. The Appellant’s appeal against the said Order was rejected by the Commissioner (Appeals), leading to Appeal No. ST/40911/2015 filed along with an application for additional evidence.

2.1 Appeals Nos. ST/41709 to 41712/2016 arise from SCN’s for the periods 2010-11, 2011-12, July 2012 to September 2013, and October 2013 to September 2014, for the same activity, demanding service tax along with interest and penalties. These demands were confirmed by the Adjudicating Authority and upheld by the Commissioner (Appeals), giving rise to the present appeals.

2.2 The appellant filed Miscellaneous Application (M.A.) No. ST/MISC/40057/2025 in Appeal No. 40911/2015, placing on record documents to substantiate that vocational training imparted by a VTI was exempt from service tax under Notification No. 24/2004-ST dated

10.09.2004. The said notification was amended by Notification No. 03/2010-ST dated 27.02.2010, which, as per the Appellant, took effect only from the date of its publication in the Gazette of India on

22.01.2011.

3. The learned Advocate Shri Raghavan Ramabhadran appeared for the appellant and Ld. Authorized Representative Smt. Anandalakshmi Ganeshram, appeared for the respondent.

3.1 Shri Raghavan Ramabhadran Ld. Counsel for the appellant submitted two Tables showing a summary of the demand involved (Table - I), and the issues under dispute (Table - II), in both the appeals. Table -II summarises the findings by the Revenue and their (appellants) response in brief. The same are reproduced below:

Table I: Summary of Demand TABLE -II The Ld. Counsel further submitted that the courses on which the exemption was denied are:

a. 2 Year Post Graduate Diploma Courses on Direction b. 2 Year Post Graduate Diploma Courses on Cinematography c. 1 Year Post Graduate Diploma in Editing & Sound Design rendered in collaboration with Arcadia University I. Period: 01.04.2005 to 26.02.2010 (Impugned OIA dated

10.02.2015 – ST/40911/2015)

A. The exemption was denied on the grounds that:

(i) the film industry does not require the qualifications provided; (ii) the Appe