“5. ...In fact, in para 9 of Ext.P9, the respondent authority has, after examining the contentions of the University and relevant facts and legal provisions, categorically held that “the University of Calicut is covered by the jurisdiction of the Finance Act 1994”. Further, it can be seen from Paras 5 to 8 of Ext.P9, that the respondent authority had conducted a preliminary analysis of various contentions raised by the University in support of their claim that they are not liable to pay service tax and given reasons why the same may be invalid, leading to the observation in para 9 that p rima facie , there appears to be a strong case against the University and, in order to examine the University's claims with regard to applicability of exemptions claimed or non-applicability of service tax, in detail, the University needs to furnish the documents and details considered necessary by the investigating officers.” 11. ….It can also be seen that the petitioner seems to be under the impression that the direction to the respondent authority in the judgment 22.3.2017 was to pass an order regarding the applicability of service tax (or coverage of service tax) on the university (rather than the coverage of Finance Act, 1994 on the University as mentioned in the judgment). The above interpretation of the petitioner appears to be erroneous for the simple reason that the primary purpose of the inquiry initiated was to confirm or rule out the applicability of service tax on the University, and such an interpretation would render the said inquiry meaningless, and require the respondent authority to pass an order in violation of the provisions and
