Dear Experts,
My client was discharging Service Tax from his Service Tax registration in Delhi. Another Service tax number was wrongly allotted to him from Lucknow. Our client has given proper application of surrender to jurisdictional officer in March 2017 for wrongly allotted ST Number. In July 2020, based on 3rd party data (26AS), Letter was issued from Lucknow for inquiry of payment of Service Tax against which reply stating the fact that Service Tax was discharged from registered office in Delhi on 25-08-2020.
Show Cause notice was issued demanding full Service tax, Interest & penalty without considering reply submitted by us. Show cause notice was not delivered to client as address mentioned in wrongly allotted Service tax number is not being used by client. on 12-04-2022, order of Asst Comm (Adj) was handed over to client confirming demand of Service Tax, Interest and penalty wherein it is clearly mentioned that in-spite of sending many letters, no reply was submitted by assessee whereas reply was first letter was submitted. Now my client has no option except filing appeal
this would be my first case of appeal hence request to experts to guide:
1. How to draft Statement of Facts, Ground of appeal and prayer (if draft can be shared for similar case or other case of Service tax, it would be very helpful)
2. Whether Appeal to be filed in ST-4 as per earlier law.
3. What other thinks should be taken care of while perusing the case.

Thanks in advance

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Regards
Fareed

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thanks in advance

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