Commissioner of Central Excise and Service Tax Vs M/S Corporation Bank — Karnataka HC (2026) — LawSathi Research

Commissioner of Central Excise and Service Tax Vs M/S Corporation Bank — Karnataka HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

No relief to the Revenue-appellants: the substantial questions of law were answered in favour of the assessee-banks and against the Revenue, and CEA Nos. 2, 3, 7, 8, 9, 10, 11 and 12 of 2022 stand dismissed, leaving the impugned CESTAT Final Orders (within Common Final Order No. 20691-20708/2020 dated 23/09/2020) undisturbed.

Issue for consideration

Whether the CESTAT was right in setting aside the OIOs and allowing the assessee-banks' appeals by holding that the banks are eligible to avail Cenvat credit of Service Tax paid on the premium amount for the Insurance Service received by the banks from the Deposit Insurance and Credit Guarantee Corporation (admitted for C.E.A Nos. 02 and 03/2022). +7 more

Ratio / Principle

The questions of law raised in these appeals are no longer res integra: they stand answered by the judgment of the High Court of Kerala (in M/s South Indian Bank), and this Court finds no grounds and reasons to take a different view from the view taken by the High Court of Kerala.

Key takeaways

The Revenue's submission that the reliance placed on this Court's judgment in PNB MetLife India Insurance Co. Ltd. was misplaced/inapplicable is of no consequence: the Kerala High Court gave substantial consideration to the regulatory framework governing the grant and continuance of banking licences, the reference to PNB MetLife is only incidental, and the Revenue's submissions do not substantiate the need for any further examination of the controversy.ratio¶158
Following the judgment of the High Court of Kerala in M/s South Indian Bank (C.E. Appeal No.1/2021, decided 05.12.2022), the Court answers all the admitted substantial questions of law in favour of the assessees and against the Revenue; consequently the CESTAT final orders allowing the banks Cenvat credit of Service Tax on DICGC deposit-insurance premiums stand undisturbed, and all the appeals are dismissed.ratio¶165

Detailed headnote1 paragraphs

HIGH COURT OF KARNATAKA (Bengaluru), 23.04.2026 — Oral judgment (per K. V. Aravind J.; bench S.G. Pandit & K.V. Aravind JJ.). Eight Revenue appeals under Section 35G, Central Excise Act — CEA Nos. 2, 3, 7, 8, 9, 10, 11 & 12 of 2022 — by Commissioners of Central Excise/Central Tax (Mangalore; Bangalore North GST; Banashankari; Bengaluru South) against Corporation Bank, State Bank of Mysore, Bank of Baroda (erstwhile Vijaya Bank), Canara Bank, Syndicate Bank and Karnataka Bank Ltd., challenging CESTAT (South Zonal Bench, Bengaluru) Final Orders dated 23/09/2020 (within Common Final Order No. 20691-20708/2020) which, following the CESTAT Larger Bench order in South Indian Bank v. Commissioner of Customs, Central Excise & Service Tax, Calicut (interim order 1331/2020 dated 20.03.2020), had allowed the banks Cenvat credit of Service Tax paid on Deposit Insurance and Credit Guarantee Corporation (DICGC) insurance premiums as an 'input service'. Substantial questions admitted 03.08.2022 asked (for CEA 2 & 3) whether CESTAT was right in allowing such Cenvat credit and in relying on the Larger Bench; and (for CEA 7-12) whether banking as 'transactions in money only' is a 'service'/output service under the Finance Act, 1994; whether mandatory deposit insurance is an 'input service'; the reinsurance analogy; and the position after Notification No. 3/2011 dated 01.04.2011 omitted 'activities relating to business'. Court: the questions are 'no longer res integra', having been answered by the High Court of Kerala in The Principal Commissioner of Central Tax and Central Excise v. M/s South Indian Bank, 2022:KER:76979 (C.E. Appeal No.1/2021, decided 05.12.2022), affirming the Larger Bench after reference to the Banking Regulation Act, 1949; the Bombay High Court had likewise answered for the assessees in Commissioner of CGST and Central Excise v. Yes Bank Ltd (Central Excise Appeal No.21/2021, 12.09.2023). The Revenue's attempt to distinguish via this Court's PNB MetLife India Insurance Co. Ltd. [2015 (39) STR 561 (Kar)] was rejected — the reference being 'only incidental' and the objection 'of no consequence'. All questions answered in favour of the assessees and against the Revenue; all appeals DISMISSED. (The Revenue had noted that the Kerala/Bombay High Court judgments were pending in appeal before the Supreme Court.)

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23^RD DAY OF APRIL, 2026

PRESENT

THE HON'BLE MR. JUSTICE S.G.PANDIT

AND

THE HON'BLE MR. JUSTICE K. V. ARAVIND CENTRAL EXCISE APPEAL No.9 OF 2022

C/W

CENTRAL EXCISE APPEAL No.2 OF 2022 CENTRAL EXCISE APPEAL No.3 OF 2022 CENTRAL EXCISE APPEAL No.7 OF 2022 CENTRAL EXCISE APPEAL No.8 OF 2022

CENTRAL EXCISE APPEAL No.10 OF 2022 CENTRAL EXCISE APPEAL No.11 OF 2022 CENTRAL EXCISE APPEAL No.12 OF 2022

IN CEA No.9/2022

Digitally signed by VINUTHA B S Location: High Court of Karnataka

BETWEEN:

COMMISSIONER OF CENTRAL EXCISE AND SERVICE TAX, 7^TH FLOOR, TRADE CENTRE, BUNTS' HOSTEL ROAD, MANGALORE-575003.

…APPELLANT

(BY SRI ARAVIND V CHAVAN, ADVOCATE)

AND:

M/S CORPORATION BANK, CORPORATE OFFICE/HEAD OFFICE, MANGALA DEVI TEMPLE ROAD,

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HC-KAR

PANDESHWAR, MANGALORE-575001.

…RESPONDENT

(BY SRI G. SHIVADAS, SENIOR COUNSEL FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE)

THIS CEA / CENTRAL EXCISE APPEAL UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, PRAYING TO ANSWER THE SUBSTANTIAL QUESTIONS OF LAW FRAMED ABOVE IN FAVOUR OF THE APPELLANT IN THE INTEREST OF JUSTICE AND EQUITY. SET ASIDE THE IMPUGNED FINAL ORDER No.A/20704/2020 DATED 23/09/2020 PASSED IN ST/20423/2017 (IN COMMON FINAL ORDER No.2069120708/2020) BY THE HON'BLE CESTAT, SOUTH ZONAL BENCH, BENGALURU, VIDE ANNEXURE-A, IN THE INTEREST OF JUSTICE AND EQUITY ETC.

IN CEA No.2/2022

BETWEEN:

THE PRINCIPAL COMMISSIONER OF CENTRAL TAX - GST, BANGALORE NORTH COMMISSIONERATE, No.59, GROUND FLOOR, HMT BHAVAN, GANGA NAGAR, BANGALORE-560032.

...APPELLANT

(BY SRI NEERALGI JEEVANBABU JAGADISH, ADVOCATE)

AND:

M/S STATE BANK OF MYSORE, (REFERRED AS SBM/ASSESSEE), HEAD OFFICE: MYSORE BANK CIRCLE, KEMPEGOWDA ROAD, BANGALORE 560009.

...RESPONDENT

(BY SRI G. SHIVADAS, SENIOR COUNSEL FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE)

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HC-KAR

THIS CEA / CENTRAL EXCISE APPEAL UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, ARISING OUT OF ORDER DATED 23/09/2020 PASSED IN FINAL ORDER No.20708/2020. PRAYING TO ALLOW THE APPEAL OF THE APPELLATE AND DECIDE THE QUESTIONS OF LAW AS FRAMED ABOVE.B. SET ASIDE THE IMPUGNED FINAL ORDER BEARING No. 20708/2020 DATED 23/09/2020 PASSED BY THE CESTAT, SOUTH ZONAL BENCH, BENGALURU.

IN CEA No.3/2022

BETWEEN:

THE PRINCIAL COMMISSIONER OF CENTRAL TAX - GST, BANGALORE NORTH COMMISSIONERATE, No.59, GROUND FLOOR, HMT BHAVAN, GANGA NAGAR, BANGALORE-560032.

...APPELLANT

(BY SRI NEERALGI JEEVANBABU JAGADISH, ADVOCATE)

AND:

M/S BANK OF BARODA, (FORMERLY VIJAYA BANK), (REFERRED AS BOB/ASSESSEE), HEAD OFFICE: 41/2, MG ROAD, BANGALORE 560001.

...RESPONDENT

(BY SRI G. SHIVADAS, SENIOR COUNSEL FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE)

THIS CEA / CENTRAL EXCISE APPEAL UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, ARISING OUT OF ORDER DATED 23/09/2020 PASSED IN FINAL ORDER No.A/20692 AND 20696/2020. PRAYING TO ALLOW THE APPEAL OF THE APPELLANT AND DECIDE THE QUESTIONS OF LAW AS FRAMED ABOVE. SET ASIDE THE IMPUGNED FINAL ORDER BEARING No.A/20692 AND 20696/2020 DATED 23/09/2020 PASSED BY THE CESTAT, SOUTH ZONAL BENCH, BENGALURU .

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HC-KAR

IN CEA No.7/2022

BETWEEN:

PRINCIPAL COMMISSIONER OF CENTRAL EXCISE AND SERVICE TAX, JSS TOWERS, 100 FEET RING ROAD, BANASHANKARI III STAGE, BANGALORE-560 085.

CHIEF COMMISSIONER OF CENTRAL EXCISE AND SERVICE TAX, JSS TOWERS, 100 FEET RING ROAD, BANASHANKARI III STAGE, BANGALORE-560 085.

COMMISSINER OF CENTRAL TAX C.R. BUILDING, QUEENS ROAD, BENGALURU SOUTH COMMISSIONERATE, BANGALORE-560 001.

...APPELLANTS

(BY SRI NEERALGI JEEVANBABU JAGADISH, ADVOCATE)

AND:

M/S. CANARA BANK, No.51, BGSE TOWERS, 1ST CROSS, J.C. ROAD, WILSON GARDEN, BANGALORE-560 027.

...RESPONDENT

(BY SRI G. SHIVADAS, SENIOR COUNSEL FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE)

THIS CEA / CENTRAL EXCISE APPEAL UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, PRAYING TO ANSWER THE SUBSTANTIAL QUESTIONS OF LAW FRAMED ABOVE IN FAVOUR OF THE APPELLANTS IN THE INTEREST OF JUSTICE AND EQUITY. SET ASIDE THE IMPUGNED FINAL ORDER No. A/20692, 20696, 20706 & 20707/2020 (ARISING OUT OF COMMON ORDER No.A20691-20708/2020 DATED 23/09/2020

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HC-KAR

IN ST/22135/2015, ST/21795/2016, ST/21030/2019 AND ST/21031/2019 PASSED BY THE CESTAT, SOUTH ZONAL BENCH, BENGALURU.

IN CEA No.8/2022

BETWEEN:

COMMISSIONER OF CENTRAL EXCISE AND SERVICE TAX, 7^TH FLOOR, TRADE CENTRE, BUNTS HOSTEL ROAD, MANGALORE 575003.

...APPELLANT

(BY SRI ARVIND V. CHAVAN, ADVOCATE)

AND:

M/S CORPORATION BANK, CORPORATE OFFICE/HEAD OFFICE, MANGALA DEVI TEMPLE ROAD, PANDESHWAR, MANGALORE 575001.

...RESPONDENT

(BY SRI G. SHIVADAS, SENIOR COUNSEL FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE)

THIS CEA / CENTRAL EXCISE APPEAL UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, ARISING OUT OF ORDER DATED 23/09/2020 PASSED IN FINAL ORDER No. A/20699/2020 PASSED IN ST/20152/2017 (IN COMMON FINAL ORDER No. 20691-20708/2020) PRAYING TO ANSWER THE SUBSTANTIAL QUESTIONS OF LAW FRAMED ABOVE IN FAVOUR OF THE APPELLANT IN THE INTEREST OF JUSTICE AND EQUITY. SET ASIDE THE IMPUGNED FINAL ORDER No. A/20699/2020 DATED 23/09/2020 PASSED IN ST/20152/2017 (IN COMMON FINAL ORDER No.20691-20708/2020) BY THE

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HON'BLE CESTAT, SOUTH ZONAL BENCH, BENGALURU, VIDE ANNEXURE-A.

IN CEA No.10/2022

BETWEEN:

COMMISSIONER OF CENTRAL EXCISE AND CENTRAL TAX, 7^TH FLOOR, TRADE CENTRE, BUNTS HOSTEL ROAD, MANGALORE-575003.

...APPELLANT

(BY SRI ARVIND V. CHAVAN, ADVOCATE)

AND:

M/S SYNDICATE BANK, CORPORATE OFFICE, AUDIT AND TAX CELL, II CROSS, GANDHINAGAR, BENGALURU - 560 009.

...RESPONDENT

(BY SRI G. SHIVADAS, SENIOR COUNSEL FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE)

THIS CEA / CENTRAL EXCISE APPEAL UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, PRAYING TO ANSWER THE SUBSTANTIAL QUESTIONS OF LAW FRAMED ABOVE IN FAVOUR OF THE APPELLANT IN THE INTEREST OF JUSTICE AND EQUITY. SET ASIDE THE IMPUGNED FINAL ORDER No.A/20702/2020 DATED 23/09/2020 PASSED IN ST/20263/2017 (IN COMMON FINAL ORDER No.2069120708/2020) BY THE HON'BLE CESTAT, SOUTH ZONAL BENCH, BENGALURU, VIDE ANNEXURE-A, IN THE INTEREST OF JUSTICE AND EQUITY.

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HC-KAR

IN CEA No.11/2022

BETWEEN:

COMMISSIONER OF CENTRAL EXCISE AND CENTRAL TAX, 7^TH FLOOR, TRADE CENTRE, BUNTS HOSTEL ROAD, MANGALORE-575003.

...APPELLANT

(BY SRI ARVIND V. CHAVAN, ADVOCATE)

AND:

M/S KARNATAKA BANK LTD., MAHAVEERA CIRCLE, PUMPWELL, KANKANADY, MANGALORE-575002.

...RESPONDENT

(BY SRI G. SHIVADAS, SENIOR COUNSEL FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE)

THIS CEA / CENTRAL EXCISE APPEAL UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, PRAYING TO ANSWER THE SUBSTANTIAL QUESTIONS OF LAW FRAMED ABOVE IN FAVOUR OF THE APPELLANT IN THE INTEREST OF JUSTICE AND EQUITY. SET ASIDE THE IMPUGNED FINAL ORDER No.A/20703/2020 DATED 23.09.2020 PASSED IN ST/20415/201 (IN COMMON FINAL ORDER No.2069120708/2020) PASSED BY THE HON'BLE CESTAT, SOUTH ZONAL BENCH, BENGALURU VIDE ANNEXURE-A.

IN CEA No.12/2022

BETWEEN:

COMMISSIONER OF CENTRAL EXCISE AND SERVICE TAX 7^TH FLOOR, TRADE CENTRE,

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HC-KAR

BUNTS HOSTEL ROAD, MANGALORE 575003.

...APPELLANT

(BY SRI ARVIND V. CHAVAN, ADVOCATE)

AND:

M/S KARNATAKA BANK, MAHAVEERA CIRCLE, PUMPWELL, KANDANADY, MANGALORE 575002.

...RESPONDENT

(BY SRI G. SHIVADAS, SENIOR COUNSEL FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE)

THIS CEA / CENTRAL EXCISE APPEAL UNDER SECTION 35G OF THE CENTRAL EXCISE ACT, PRAYING TO ANSWER THE SUBSTANTIAL QUESTIONS OF LAW FRAMED ABOVE IN FAVOUR OF THE APPELLANT IN THE INTEREST OF JUSTICE AND EQUITY. SET ASIDE THE IMPUGNED FINAL ORDER No.A/20698/2020 DATED 23/09/2020 PASSED IN ST/20151/2017 (IN COMMON FINAL ORDER No.A/2069120708/2020) PASSED BY THE HON'BLE CESTAT, SOUTH ZONAL BENCH, BENGALURU VIDE ANNEXURE-A.

THESE APPEALS, COMING ON FOR HEARING THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:

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

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HC-KAR

ORAL JUDGMENT

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

Heard Sri. Aravind.V.Chavan, learned Senior Standing Counsel for the appellants and Sri. G.Shivadas, learned Senior Counsel on behalf of Smt. Tanmayee Rajkumar, learned counsel for the respondent.

All these appeals are filed by the Revenue and raise common questions of law. The learned Senior Standing Counsel and the learned Senior Counsel appearing for the respective parties advanced common arguments. Accordingly, all these appeals are disposed of by this common order.

This Court vide order dated 03.08.2022 admitted the following substantial questions of law for consideration, which read as under:

In C.E.A Nos.02 and 03/2022

(i) Whether the CESTAT was right in setting aside the OIOs and allowing the appeals of the assesses, by holding that the banks are eligible to avail Cenvat credit of Service Tax paid on the premium amount for the Insurance Service received by the banks from ‘Deposit Insurance and Credit Guarantee Corporation’.

(ii) Whether CESTAT was right in placing reliance on the Larger Bench Decision of the Hon’ble Tribunal, Bangalore

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HC-KAR

in the assessee-banks’ own case vide interim order 1331/2020 dated 20.03.2020, which held that a commercial bank is entitled to treat insurance services provided by ‘Deposit Insurance and Credit Guarantee Corporation’ (DICGC) as an input service and is entitled to take Cenvat credit of Service Tax paid upon receipt of such service.

In C.E.A Nos.07, 08, 09, 10, 11 and 12/2022

(i) Whether the Tribunal is right in considering that the activity of business of banking, viz., "transactions in money only" as "services" within the ambit of the Finance Act, 1994?

(ii) Whether the Tribunal is right in further considering the above activity of business of banking as an output service within the ambit of the Finance Act, 1994, especially when no service charges were collected by banks for transactions in money only?

(iii) Whether the Tribunal is right in extending deposit insurance scheme as an input service when essentially there was no service at all by banks, and therefore no output services also, in the business of banking, i.e., when the business of banking was transactions in money only?

(iv) Whether the Tribunal is right in extending deposit insurance scheme as an "input service" merely because it is mandatory and without deposit insurance banks cannot function at all?

(v) Whether the Tribunal is right in equating reinsurance service, which is mandatory and which is for insurance, which is a service, with deposit insurance, which, though mandatory, is not linked to any output service or for that matter any service vis-à-vis the business of banking?

(vi) Whether the Tribunal is right in allowing the CENVAT credit on deposit insurance even after omission of the general entry activities relating to business from the definition of input services vide Notification No. 3/2011 dated 01.04.2011?

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HC-KAR

The facts in C.E.A No.11/2022 are referred to for convenience.

At the outset, Sri G. Shivadas, learned Senior Counsel appearing for the respondent, submitted that the Customs, Excise and Service Tax Appellate Tribunal (for short, ‘CESTAT’), while answering the controversy in favour of the assessee, had followed the order of the Larger Bench of CESTAT in South Indian Bank vs. Commissioner of Customs, Central Excise

& Service Tax, Calicut .

5.1 It was further submitted that the order of the Larger Bench was the subject matter of appeal before the High Court of Kerala in The Principal Commissioner of Central Tax and Central Excise vs. M/s South Indian Bank 2022:KER:76979 . It is submitted that the High Court of Kerala, by judgment dated 05.12.2022 in C.E. Appeal No.1/2021 and connected matters, answered the questions in favour of the assessee and against the Revenue by affirming the order of the Larger Bench of the CESTAT.

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5.2 It is also submitted that the Bombay High Court answered the questions in favour of the assessee in Commissioner of CGST and Central Excise vs. Yes Bank Ltd . in Central Excise Appeal No.21/2021 dated 12.09.2023, following the judgment of the High Court of Kerala in the case of M/s South Indian Bank ( supra ). It is further submitted that, in view of the judgments of the High Court of Kerala and the Bombay High Court, the questions of law arising in these appeals ought to be answered in favour of the assessee and against the Revenue.

Sri Jeevan J. Neeralgi and Sri Aravind V. Chavan, learned Senior Standing Counsel appearing for the appellants–Revenue, submit that the judgments of the High Courts on the identical issue are pending consideration in appeal before the Supreme Court of India.

6.1 Sri Jeevan J. Neeralgi, learned Senior Standing Counsel, submits that the reliance placed on the judgment of this Court in Commissioner of Central Excise, Bangalore v. PNB

MetLife India Insurance Co. Ltd. [2015 (39) STR 561 (Kar)] is misplaced and that the said decision is inapplicable to the facts of the present cases. On the strength of the above

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submission, the learned Senior Standing Counsel seeks to distinguish the judgment of the High Court of Kerala.

We have considered the submissions made by the learned Senior Standing Counsels for the appellants-revenue and learned Senior Counsel for the respondent-assessee.

On a perusal of the impugned order, it is evident that the Tribunal, following the order of the Larger Bench, allowed the appeals by answering the controversy in favour of the assessee and against the Revenue. The order of the Larger Bench was the subject matter of consideration before the High Court of Kerala in the case of M/s South Indian Bank ( supra ).

8.1 The High Court of Kerala, by judgment dated 05.12.2022 in C.E. Appeal No.1/2021 and connected matters, after an extensive analysis of the reasoning assigned by the Larger Bench, including reference to the Banking Regulation Act, 1949, answered the questions in favour of the assessee, thereby affirming the order of the Larger Bench. Similar questions have also been answered by the Bombay High Court, following the judgment of the High Court of Kerala.

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8.2 The submission of the learned Senior Standing Counsels appearing for the appellants–Revenue that reliance placed on the judgment of this Court in the case of PNB MetLife India Insurance Co. Ltd. ( supra ) is incorrect, is of no consequence. The High Court of Kerala has noticed that substantial consideration was given to the nature of, and the requisite compliances to be adhered to by, banks in terms of the regulatory framework governing the grant and continuance of a banking licence. The reference to PNB MetLife India Insurance Co. Ltd. ( supra ) is only incidental. The submissions made by the learned Senior Standing Counsels appearing for the appellants–Revenue do not substantiate the need for any further examination of the controversy in question.

8.3 On a perusal of the impugned order and upon considering

the judgment of the High Court of Kerala, we are of the view that the questions raised in these appeals are no longer res integra and stand answered by the judgment of the High Court of Kerala. We find no grounds and reasons to take a different view from the view taken by the High Court of Kerala.

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HC-KAR

In the light of the above, by following the judgment in the

case of M/s South Indian Bank ( supra ) in C.E. Appeal No.1/2021 decided on 05.12.2022, we answer the substantial questions of law framed herein in favour of the assessee and against the Revenue. Accordingly, the appeals stand

dismissed .

Sd/(S.G.PANDIT) JUDGE

Sd/(K. V. ARAVIND) JUDGE

SMJ/ List No.: 1 Sl No.: 38

Parties & counsel

AI extract

appellant
Commissioner of Central Excise and Service Tax, Mangalore (appellant in CEA No. 9 of 2022)¶14
Aravind V. Chavan
respondent
M/s Corporation Bank, Mangalore (respondent in CEA No. 9 of 2022)¶18
G. Shivadas (Sr.), Tanmayee Rajkumar
appellant
The Principal Commissioner of Central Tax - GST, Bangalore North Commissionerate (appellant in CEA No. 2 of 2022)¶28
Neeralgi Jeevanbabu Jagadish
respondent
M/s State Bank of Mysore (referred as SBM/assessee) (respondent in CEA No. 2 of 2022)¶32
G. Shivadas (Sr.), Tanmayee Rajkumar
appellant
The Principal Commissioner of Central Tax - GST, Bangalore North Commissionerate (appellant in CEA No. 3 of 2022)¶41
Neeralgi Jeevanbabu Jagadish
respondent
M/s Bank of Baroda (formerly Vijaya Bank) (referred as BOB/assessee) (respondent in CEA No. 3 of 2022)¶45
G. Shivadas (Sr.), Tanmayee Rajkumar
appellant
Principal Commissioner of Central Excise and Service Tax, Banashankari, Bangalore (appellant No. 1 in CEA No. 7 of 2022)¶53
Neeralgi Jeevanbabu Jagadish
appellant
Chief Commissioner of Central Excise and Service Tax, Banashankari, Bangalore (appellant No. 2 in CEA No. 7 of 2022)¶54
Neeralgi Jeevanbabu Jagadish
appellant
Commissioner of Central Tax, Bengaluru South Commissionerate, C.R. Building, Queens Road (appellant No. 3 in CEA No. 7 of 2022)¶55
Neeralgi Jeevanbabu Jagadish
respondent
M/s Canara Bank, Bangalore (respondent in CEA No. 7 of 2022)¶59
G. Shivadas (Sr.), Tanmayee Rajkumar
appellant
Commissioner of Central Excise and Service Tax, Mangalore (appellant in CEA No. 8 of 2022)¶69
Aravind V. Chavan
respondent
M/s Corporation Bank, Mangalore (respondent in CEA No. 8 of 2022)¶73
G. Shivadas (Sr.), Tanmayee Rajkumar
appellant
Commissioner of Central Excise and Central Tax, Mangalore (appellant in CEA No. 10 of 2022)¶82
Aravind V. Chavan
respondent
M/s Syndicate Bank, Bengaluru (respondent in CEA No. 10 of 2022)¶86
G. Shivadas (Sr.), Tanmayee Rajkumar
appellant
Commissioner of Central Excise and Central Tax, Mangalore (appellant in CEA No. 11 of 2022)¶95
Aravind V. Chavan
respondent
M/s Karnataka Bank Ltd., Mangalore (respondent in CEA No. 11 of 2022)¶99
G. Shivadas (Sr.), Tanmayee Rajkumar
appellant
Commissioner of Central Excise and Service Tax, Mangalore (appellant in CEA No. 12 of 2022)¶105
Aravind V. Chavan
respondent
M/s Karnataka Bank, Mangalore (respondent in CEA No. 12 of 2022)¶113
G. Shivadas (Sr.), Tanmayee Rajkumar

Coram

AI extract

S.G. Panditmember¶118
K. V. Aravindauthor¶122