THIS CEA IS FILED UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, PRAYING TO SET ASIDE THE IMPUGNED ORDER No.21793/2024 PRONOUNCED ON 29.10.2024 RECEIVED ON 21.01.2026 (ANNEXURE A) PASSED BY THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL, REGIONAL BENCH AT BENGALURU IN SERVICE TAX APPEAL No.ST/21041/2019.

THIS APPEAL, COMING ON FOR ADMISSION THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and HON'BLE MR. JUSTICE K. V. ARAVIND

ORAL JUDGMENT

(PER: HON'BLE MR. JUSTICE K. V. ARAVIND)

Heard Sri. S.P. Harish, learned counsel for the appellant and Sri. Jeevan J. Neeralgi, learned Senior Standing counsel for respondents-revenue.

2. This appeal is filed by the appellant impugning the order passed in Service Tax Appeal No. 21041/2019, Final Order No. 21793/2024 dated 29.10.2024, by the Customs, Excise and Service Tax Appellate Tribunal, Bangalore (for short, “the Tribunal”).

3. The following substantial questions of law are raised for the consideration of this court:

(i) Whether the Tribunal's order pronounced on 29.10.2024 and received on 21.01.2026 is vitiated in law for being perverse, cryptic, non-reasoned, and non-speaking, thereby violating the principles of natural justice and raising a substantial question of law within the meaning of Section 35G of the Central Excise Act, 1944?

(ii) Whether the Tribunal erred in law by failing to properly consider the appellant's submissions (as recorded in para 8-16 of the order) and by confirming the demand on baseless and conclusory grounds in para 19 without providing cogent reasons, thereby amounting to non-application of mind and perversity?

(iii) Whether the Tribunal erred in law by breaching judicial discipline in failing to follow binding precedents of the Hon'ble Supreme Court, and by not providing cogent reasons for departure?

(iv) Whether the Tribunal's order suffers from internal inconsistency in setting aside the extended period of limitation and penalty under Section 78 of the Finance Act, 1994, while simultaneously confirming the demand for the normal period without explaining why the same reasoning did not vitiate the entire demand?

(v) Whether the Tribunal erred in law by pronouncing its order after an inordinate delay of nearly six months from the date of reserving judgment (30.04.2024 to 29.10.2024), contrary to the principle of prompt adjudication thereby undermining judicial discipline and raising a substantial question of law?"

4. Sri P.B. Harish, learned counsel appearing for the appellant, submits that the Tribunal has not consider the contentions urged by the appellant and has recorded no findings thereon. Learned counsel, without prejudice to the submissions made on merits, further submits that the matter requires reconsideration by the Tribunal.

5. Per contra, Sri Jeevan J. Neeralgi, learned Senior Standing Counsel appearing for the Revenue, submits that the conclusion of the Tribunal is based on due consideration of the submissions made and the contentions urged by the appellant, and that no interference is warranted.

6. Having considered the submissions made by learned counsel for the appellant and the Revenue, and upon perusal of the contentions urged by the appellant as recorded in the impugned order passed by the Tribunal, we find that the findings recorded by the Tribunal in paragraph No.19 do not address all the contentions and issues raised by the appellant. The Tribunal, being the final fact-finding authority, is required to consider and analyse the entire factual matrix involved in the matter.

7. We find it difficult to answer the questions raised in the present appeal on the basis of the findings recorded by the Tribunal. As the findings of the Tribunal do not reflect consideration of all the issues raised, the matter requires reconsideration by the Tribunal.

8. In the light of the above, without answering the questions raised in the present appeal