The Commissioner of GST & Central Excise (Appeals–Thane), Mumbai had upheld the denial, leading to the present appeal. The Department’s Authorized Representative reiterated the contents of the impugned order and submitted that the Supreme Court decision was required to be followed. Ltd. vs. Commissioner of Service Tax, Delhi , (2023) 9 Centax 362 (Tri.-Chan)HDFC Bank Ltd. v. Commissioner of Central Excise, Thane-II , 2021 (44) G.S.T.L. 155 (Tri.- Mumbai)Ecko Cables (P) Ltd. vs. Commissioner of Central Excise and Service Tax, Ludhiana , Final Order No. The interpretation of the judgment of the Supreme Court by the High Courts as above throws light on the controversy.