This compilation indexes twelve rulings pronounced by the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) between June 2025 and March 2026, each engaging Section 65 of the Finance Act, 1994 — the definitional provision that underpins the entire service tax regime — alongside related charging, valuation, and penalty provisions. The compilation is intended for tax counsel, Big-4 indirect-tax practitioners, in-house indirect-tax teams, and legal researchers who need a structured, citation-ready reference to recent CESTAT dispositions on service tax classification and allied issues.

Research index only. This page is a structured case-law reference. Nothing on this page constitutes legal or tax advice. Readers must independently verify each ruling against the full judgment text, check for any stay, reversal, or higher-court proceedings, and consult qualified counsel before acting on any information.

The statutory framework in one paragraph

Section 65 of the Finance Act, 1994, is the master definitions provision for the erstwhile service tax regime. It enumerates the meanings assigned to terms used throughout the Act — including the definitions of specific "taxable services" under Section 65(105) and its numerous sub-clauses — and provides the definitional foundation upon which the charging section (Section 66/66B), valuation provision (Section 67), and demand-and-penalty machinery (Sections 73, 75, 76, 77, 78) operate. Although the service tax regime has been subsumed into GST with effect from 1 July 2017, legacy demands, appeals, and adjudications under the Finance Act, 1994 continue to be litigated before CESTAT and the courts, making Section 65 jurisprudence actively relevant for the resolution of pre-GST disputes.

The 12 rulings

1. G R Thanga Maligai vs Cst Ch

Bench: Custom, Excise & Service Tax Tribunal
Date: 20 March 2026
Sections engaged: 65(105)(zzzn), 66A, 67, 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 40699 of 2016, arising from Order-in-Appeal No. 374/2015 (STA-II) dated 29-12-2015) was filed before the CESTAT Chennai Regional Bench. Per the source preview, the appellant is engaged in the sale of gold jewellery and had entered into a 'Co-Op Partner Agreement' with the World Gold Council (WGC) to jointly promote the sale of 22-karat gold jewellery through media advertisement; WGC agreed to share a portion of media payment obligations subject to compliance with WGC strategy and brand elements. The substantive issue relates to the taxability and valuation of the arrangement under the sections cited; the final outcome is not specified in the source preview.

2. Chikmagalur Golf Club vs Mysore

Bench: Custom, Excise & Service Tax Tribunal
Date: 10 March 2026
Sections engaged: 12A, 65(105), 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 145 of 2012, arising from Order-in-Original No. 07/ST/2011 dated 11.10.2011) was filed before the CESTAT Bangalore Regional Bench against an order of the Commissioner of Central Excise, Customs and Service Tax, Mysore. Per the source preview, the Department initiated proceedings alleging that the appellant provided taxable services under the category of 'Club or Association Service' but failed to discharge service tax of Rs. 52,85,307/- during the period 16.06.2005 to 31.03.2009; on adjudication the Commissioner reduced the demand to Rs. 50,98,330/- with interest and equivalent penalty. The appellant contended that it is a charitable trust registered with the objective of promoting golf and other games and tourism. The final outcome is not specified in the source preview.

3. Sanmar Shippings Ltd vs Cst Ch

Bench: Custom, Excise & Service Tax Tribunal
Date: 4 March 2026
Sections engaged: 65, 66, 66A, 73(1), 76, 77, 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter comprised three consolidated appeals — Service Tax Appeal Nos. 40795–40796 of 2014 (arising from Order-in-Original Nos. 34 & 35 of 2013 dated 29-03-2013) and Service Tax Appeal No. 42337 of 2016 (arising from Order-in-Appeal No. 151/2016 (STA-II) dated 30.08.2016) — heard together before the CESTAT Chennai Regional Bench and disposed of by a common final order (Final Order Nos. 40321–40323/2026). Per the source preview, the appeals involving common issues were heard on 14.10.2025 and decided on 04.03.2026. The final outcome is not specified in the source preview.

4. Chettinad Lignite Transport Services P vs Cst Ch - Ii

Bench: Custom, Excise & Service Tax Tribunal
Date: 19 February 2026
Sections engaged: 65(105)(zr), 65(23), 65(23)(b), 65A(b), 68(1), 69, 70, 73(1), 75
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 40031 of 2016, arising from Order-in-Original No. CHN-SVTAX-002-COM-24 & 25-2015-2016 dated 12.10.2015) was filed before the CESTAT Chennai Regional Bench. Per the source preview, the Department, upon verification of the appellant's records, found that the appellant had been providing services prior to July 2012 without obtaining registration or discharging service tax; the appellant had entered into an agreement dated 16.04.2002 with M/s. ST-CMS Electric Company Private Limited to design, finance, construct, own, operate and maintain a Lignite Transportation System for the transportation of lignite from Neyveli Lignite Corporation to a power plant at Uttangal. The final outcome is not specified in the source preview.

5. Ge Global Servicing Pvt Ltd vs Rangareddy - G S T

Bench: Custom, Excise & Service Tax Tribunal
Date: 18 December 2025
Sections engaged: 65
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter comprised two appeals — Service Tax Appeal No. 22200 of 2014 (arising from Order-in-Appeal No. 77/2014 (H-IV) S.Tax dated 18.03.2014) and Service Tax Appeal No. 22202 of 2014 (arising from Order-in-Appeal No. 99/2014 (H-IV) S.Tax dated 26.03.2014) — filed before the CESTAT Hyderabad Regional Bench against orders of the Commissioner of Customs, Central Excise & Service Tax (Appeals-II), Hyderabad. The source preview is largely procedural and identifies the parties and the forum; no further substantive detail on the ground of dispute is available from the preview. The final outcome is not specified in the source preview.

6. Om Electrical vs Meerut-I

Bench: Custom, Excise & Service Tax Tribunal
Date: 18 December 2025
Sections engaged: 174, 65, 66B, 70(1), 73(1), 75, 77(1), 77(1)(c), 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 70709 of 2024, arising from Order-in-Appeal No. DDN/EXCUS/000/APPL-MRT/262/2023-24 dated 09/02/2024) was filed before the CESTAT Allahabad Regional Bench. Per the source preview, the lower authority confirmed a demand of service tax of Rs. 1,30,356/- along with applicable interest on services provided to two clients — M/s Ircon International Ltd and M/s IL&FS Engineering & Construction Co. Ltd — and confirmed penalty equal to the tax confirmed; penalties of Rs. 40,000/- and Rs. 10,000/- were also imposed for failure to file service tax returns on time and for failure to submit requisite information to the Department. The final outcome of the CESTAT appeal is not specified in the source preview.

7. Suzlon Energy Ltd vs Commissioner Of Customs Excise And

Bench: Custom, Excise & Service Tax Tribunal
Date: 10 December 2025
Sections engaged: 65, 73(1), 77
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter comprised two consolidated appeals — Service Tax Appeal Nos. 87589 and 87590 of 2013 (both arising from Order-in-Original No. 31-32/P-III/ST/COMMR/2012-13 dated 25.03.2013 passed by the Commissioner of Central Excise & Service Tax, Pune-III Commissionerate) — heard on 27.06.2025 and decided on 10.12.2025 before the CESTAT Mumbai Regional Bench (Final Order No. A/86907-86908/2025). The source preview is primarily procedural and identifies the parties and forum; the brief facts leading to the appeals are not reproduced in the available preview. The final outcome is not specified in the source preview.

8. Civil Associates vs Allahabad

Bench: Custom, Excise & Service Tax Tribunal
Date: 5 December 2025
Sections engaged: 142, 173, 174, 65, 73A, 73B, 75, 77(1)(b), 77(1)(c), 77(b), 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 70480 of 2024, arising from Order-in-Appeal No. 780/ST/Alld/2022 dated 15/03/2023) was filed before the CESTAT Allahabad Regional Bench against an order of the Commissioner (Appeals), Customs, Central Excise & Service Tax, Allahabad. Per the source preview, the lower authority's operative order dropped the demand of service tax including cess amounting to Rs. 1,10,59,914/- but confirmed interest recovery, imposed a penalty of Rs. 10,85,542/- and dropped certain charges under other provisions; the demand of interest under certain provisions and the charge of service tax collected from customers but not deposited were also dropped. The final outcome of the CESTAT appeal is not specified in the source preview.

9. M/S Matrix Design Works vs Noida

Bench: Custom, Excise & Service Tax Tribunal
Date: 1 December 2025
Sections engaged: 140, 142, 173, 174, 26, 65, 65B, 66, 66A, 66B, 73(1), 75
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 70657 of 2025, arising from Order-in-Appeal No. NOI-EXCUS-001-APP-342-24-25 dated 13/02/2025) was filed before the CESTAT Allahabad Regional Bench. Per the source preview, the Commissioner (Appeals), Central Goods & Services Tax, Noida, rejected the appellant's appeal and upheld Order-in-Original No. 228/AC/ST/TPI/CGST/Div-I/Noida/2023-24 dated 29.02.2024 passed by the Assistant Commissioner, HQ, Technical, CGST Noida, as legal and proper. The appeal before CESTAT was heard and decided on 01 December 2025 (Final Order No. 70843/2025); the final outcome of the CESTAT appeal is not specified in the source preview.

10. Itc Ltd vs Cst Ch - I

Bench: Custom, Excise & Service Tax Tribunal
Date: 26 November 2025
Sections engaged: 65, 65B(37), 65B(44), 66A, 80
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter comprised four consolidated appeals — Service Tax Appeal No. 42458 of 2015 (arising from Order-in-Appeal No. 218/2015 (STA-II) dated 25.08.2015) and Service Tax Appeal Nos. 40696, 40697, and 40936 of 2016 — filed before the CESTAT Chennai Regional Bench (Final Order Nos. 41375–41378/2025, heard 22.07.2025, decided 26.11.2025). Per the source preview, the appeals were filed by ITC Packaging and Printing Division, Chennai, arising from orders confirming demands of service tax, interest and penalty in respect of foreign currency payments made during the period 2005–2006 to 2008–09 to various foreign entities for different services. The final outcome is not specified in the source preview.

11. Commissioner Of Central Goods And vs Cci Projects P Ltd

Bench: Custom, Excise & Service Tax Tribunal
Date: 19 November 2025
Sections engaged: 119(2), 174, 65, 65B(44), 66, 66B
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter involved Service Tax Appeal No. 87297 of 2019 (arising from Order-in-Original No. 11/SKV-11/THCGST/2018-19 dated 17.09.2018 passed by the Commissioner of Central GST & Central Excise, Thane, Mumbai), accompanied by Service Tax Cross Objection No. 86322 of 2019 on behalf of the respondent and Service Tax Miscellaneous Application No. 85196 of 2022 on behalf of the appellant, filed before the CESTAT Mumbai Regional Bench. The source preview is primarily procedural, identifying the parties, forum, and related applications; no further substantive detail on the ground of dispute is available from the preview. The final outcome is not specified in the source preview.

12. Rudra Services vs Noida

Bench: Custom, Excise & Service Tax Tribunal
Date: 30 June 2025
Sections engaged: 142(8), 173, 174, 65, 73(1), 75, 77(1), 77(2), 78(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 70500 of 2024, arising from Order-in-Appeal No. NOI-EXCUS-002-APP-415-23-24 dated 13/12/2023) was filed before the CESTAT Allahabad Regional Bench. Per the source preview, the Commissioner (Appeals), CGST & Central Excise, Noida, partially allowed the appellant's earlier appeal (No. 161-ST/APPL-MRT/GZB/2022-23 dated 27.01.2023) and modified Order-in-Original No. 31/AC/CGST/GZB-II/22-23 dated 24.11.2022 passed by the Assistant Commissioner, Central GST, Division-II, Ghaziabad. The appeal before CESTAT was heard and decided on 30 June 2025 (Final Order No. 70459/2025); the final outcome of the CESTAT appeal is not specified in the source preview.

Patterns across these 12 rulings

Section 65 as the universal anchor. Every ruling in this compilation cites Section 65 of the Finance Act, 1994, confirming that definitional questions — whether a particular activity constitutes a "taxable service" and under which sub-category — remain the primary battleground in legacy service tax litigation before CESTAT.
Bundled penalty provisions. Multiple rulings engage a cluster of penalty and interest provisions alongside Section 65: Sections 73(1), 75, 77, and 78 appear together across several cases (cases 6, 8, 9, 12), reflecting the standard departmental practice of raising demand, interest, and penalty in a single adjudication order.
Transitional CGST savings provisions. Several rulings (cases 8, 9, 12) cite Sections 142, 173, and 174 of the CGST Act, 2017, alongside the Finance Act provisions, indicating that transitional and savings-clause questions — relating to the continuation and enforcement of pre-GST service tax demands — are a recurring procedural dimension in this body of litigation.
Multi-appeal consolidation. Cases 3, 7, and 10 each involved multiple appeal numbers heard and disposed of together by common order, a feature that appears frequently where the same assessee has staggered adjudications across different periods before the same CESTAT bench.
Charitable and institutional taxpayer disputes. Case 2 raises the specific question of whether a charitable-trust-registered entity providing club or association services is liable to service tax, a recurring issue in the pre-GST service tax jurisprudence that continues to surface in legacy CESTAT proceedings.

How to use this compilation

This compilation is a structured index, not a digest of final holdings. Because all twelve entries show "Outcome not specified in source," researchers must retrieve the full text of each final order from the official CESTAT portal, indiankanoon.org, or the relevant court record before drawing any conclusion about the disposition. The source previews reproduced here are extracts from the opening paragraphs of each order and do not capture the tribunal's reasoning or operative directions.

When using this index for litigation research or compliance review, verify whether any ruling has been challenged before a High Court or the Supreme Court, whether a stay has been granted, and whether any CBIC circular or instruction has been issued on the specific issue after the date of the order. Section 65 jurisprudence developed under the Finance Act, 1994 regime may interact differently with post-GST classification questions, and direct transposition of pre-GST service tax reasoning to current disputes should be approached with caution.

Researchers are also advised to check parallel CBDT or CBIC instructions, clarificatory circulars, and any advance rulings (AAR/AAAR) that may have addressed the classification or valuation question at issue in a given case, as those instruments can affect the persuasive weight of CESTAT rulings in departmental proceedings and in fresh litigation.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 65 Finance Act 1994: 12 CESTAT Rulings on Service Tax (2025–2026)