Prudeta
Prudeta
2026 INSC 723
📌 Paras 1-3.1.1
The Commissioner of Service Tax, Mumbai, appealed against a CESTAT order that had set aside service tax demands against Bharat Petroleum Corporation Limited (BPCL) and Hindustan Petroleum Corporation Limited (HPCL). The core issue was whether BPCL and HPCL's activities in selling Compressed Natural Gas (CNG) supplied by Mahanagar Gas Limited (MGL) constituted 'Business Auxiliary Service' attracting service tax. MGL supplied natural gas to BPCL/HPCL outlets, where MGL's equipment converted it to CNG. MGL paid excise duty on manufactured CNG, and agreements existed for its sale at these outlets.
📌 Para 2
Whether the activities of the respondent corporations (BPCL/HPCL) in relation to the sale of CNG supplied by Mahanaga
The bench further analyzed the constitutional validity of the impugned provisions and discussed the interpretation of Articles 14 and 21 in light of recent precedents...
Citing the ratio in prior decisions, the court held that the legislative intent was to ensure...
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