The matter was remanded to the original adjudicating authority to allow the appellant to present necessary documents and a personal hearing, ensuring compliance with the principles of natural justice.

RACHNA GUPTA

The appeal is filed to assail the order-in-original No. 007/2017-18 dated 09.05.2017 vide which the proposal of show cause notice bearing No. 145/2016 dated 20.09.2016 has been partially confirmed. The show cause notice has proposed demand of service tax amounting to Rs. 3,60,00,827/- along with the interest at the appropriate rate and the proportionate penalties under Section 77 and 78 of the Finance Act, 1994. The order under challenge has confirmed the demand of Rs. 1,17,98,923/- on following activities rendered by the appellant during the period from 01.04.2011 to 31.03.2015 :-

(i) Excess royalty collection contract with the Government of Rajasthan ;

(ii) Fly ash transportation contract of NEYVELI Lignite Corporation Limited ;

(iii) Receipt of Rs. 5,02,000/- for the year 2012-2013 from SMPL Infra Ltd.

(iv) Bad ash transportation contract of Techpro Systems Limited ;

(v) Services provided to Kerolesker Brother Ltd. viz-a-viz vehicle hire charges and construction of road;

(vi) Services provided to bridge and Roof (Co.) Ltd. viz-a-viz supply of sand and construction of road;

(vii) Service of transportation of Debris provided to Manda Developers & Pvt. Ltd. ;

(viii) Transportation of goods by road service provided to Sampat Lal Daga

(ix) Supply of sand to Ganpatlal Onkarmal Agrawal & Co.

(x) Vehicle Hire Services provided to GCKC Projects and Works Private Limited ;

(xi) Service of construction of Public Road provided to Mangalam Build-Developers Limited;

(xii) Service of construction of Public Road provided to McNally Bharat Engineering Company Limited;

(xiii) Service provided at Airport to Narbir Singh & Company;

(xiv) Road construction service provided to ABCI Infrastructure Private Limited;

(xv) Supply of Bajri to NSC Projects Private Limited;

(xvi) Work done in relation to water supply pipeline for Om Technocon Private Limited;

(xvii) Work done for Water Supply Project of Ramky Infrastructures Limited;

(xviii) Service of construction of residential house for Shobha Devi;

(xix) Service of transportation of Over Burden from mining area to dumping are provided to Sunder Lal Daga;

(xx) Service of construction of Public Utility Road provided to Thermax Limited ;

(xxi) Supply of Sand of Ajay Choudhary ;

(xxii) Transportation services provided to Janki Corp Limited;

(xxiii) Supply of Bajri.

2. Being aggrieved, the appellant is before this Tribunal.

3. We have heard Shri Sandeep Mukherjee, learned Chartered Accountant for the appellant and Ms. Jaya Kumari, learned authorized representative for the department and perused the records.

4. Learned counsel for the appellant has placed on record a chart in compliance of the directions of previous order dated 08.01.2026. It is mentioned that the chart is about several documents (31 in number) out of which many were produced before the original Adjudicating Authority, but many other as mentioned in the said chart could not be produced. It is impressed upon that all those documents are relevant for the proper adjudication of the present case. Learned counsel has requested for the matter to be remanded back. There is no apparent objection on the part of department qua the said request.

5. It is observed that service tax demand has been confirmed based on several counts. The documents tabulated in chart today reveals that appellant want to rely upon various work orders respective to the different activities under which the demand has been confirmed. This observation is sufficient for us to hold that reasonable opportunity to plead and to present all the requisite documents shall be in the interest of justice and in compliance of principles of natural justice. Accordingly, we hereby accept the