Serive tax paid on due basis not realisation base

This query is : Resolved

Querist : Anonymous

Querist : Anonymous (Querist)

30 December 2010 My client paid service tax on due base ( means when bill raised , then he will paod tax on time up to 31/03/2005.from the date of incorporation.
at the one half year the realization amount is more then bill amount , S tax officer demand on realization base143000/- on 15/04/2005. in this response i filed the letter on 15/05/2005, i clear the queries tell them because of due & realization this demand happen for department i filed last 2 year return copy where the client deposit the tax on due base, after that i filed the letter and clear that i deposit the tax on relazation base from 01/04/2005 onwards.
after that i received the letter from central excise this demand still pending on 11/11/2010,then i filed all document showing that tax was deposited on due base up to 31/03/2005, in this regard i filed 2 year return copy and letter filed on that time 15/05/2010 and clear all queries.

after that i received order that show the demand of143000/- + penality of143000/- on 24/12/2010 mention that party not clear that where we tax deposited.

Now I can go for appeal , kindly suggest me can i made ground of appeal with stick behave of normal.
thanks