CST, Delhi Respondent AND Service Tax Appeal No. 55424 of 2013 with Service tax Stay No. 55537 of 2013 (Arising out of orderinOriginal No. 28 to 29/Commr/PKL/2012 dated 18.10.2012 passed by the Commissioner of Central Excise, Panchkula). M/s Electronic and Computer Software Export Promotion Council Appellant Vs. CST, Delhi Respondent Appearance: Sh. V. Lakshmi Kumaran, Sh. B. L. Narasimhan, Ms. Sharanya & Ms. Swati Gupta, Advocates for the appellants Shri Govind Dixit and Sh. Amresh Jain, DRs for the Respondent Honble Mr. Rakesh Kumar, Technical Member Final Order Nos. 51787  51790 / 2014 Per: Justice G. Raghuram: Heard Shri V. Lakshmi Kumaran & Sh. B. L. Narasimhan, Advocates for the appellants and Shri Govind Dixit and Sh. Amresh Jain, DRs for the Respondent/ Revenue. 2. At the stage of considering the stay applications (seeking waiver of predeposit) we have heard the respective parties on the substantive issues and dispose of the appeals. We do so after waiving predeposit. 3. Service Tax Appeal Nos. 58191, 58306 and 58304 of 2013 are preferred against adjudication orders confirming levy of service tax, interest and penalties on the same appellant i.e. the Federation of India Chambers of Commerce and Commerce and Industry (in short FICCI). These appeals are directed against adjudication orders which are passed in respect of periods covering 01.07.2006 to 30.06.2010; 01.07.2010 to 30.06.2011 and 01.07.2011 to 30.06.2012, pursuant to show cause notices dated 19.10.2010; 21.10.2011 and 28.12.2012, respectively. 4. Service Tax Appeal No. 55424 of 2013 is preferred by M/s Electronic and Computer Software Export Promotion Council (in short ECSEPC), against an adjudication order dated 18.10.2012 confirming distinct and specified service tax demands for 20052009 and 2010  2011 apart from interest and penalties as specified therein. The order dated 18.10.2012 is passed pursuant to two show cause notices dated 07.10.2010 and 18.10.2011, covering the two periods in issue. 5. The assessment levy and demand of service tax, interest and penalties as specified in the several adjudication orders is predicated on the conclusion that the assessees/ appellants had provided the taxable club or association service enumerated in Section 65(105)(zzze), defined in Section 65(25a) of the Finance Act, 1994 (the Act). To the extent relevant and material for the purposes of this lis, the relevant statutory provisions are extracted: Section 65 (105) (zzze) Taxable service means any service provided or to be provided to its members, by any club or association in relation to provision of services, facilities or advantages for a subscription or any other amount; Section 65 (25a) club or association means any person or body of persons providing services, facilities or advantages, for a subscription or any other amount, to its members, but does not include: (i) Any body established or constituted by or under any law for the time being in force; or (ii) Any person or body of persons engaged in the activities of trade unions, promotion of agriculture, horticulture or animal husbandry; or (iii) Any person or body of persons engaged in any activity having objectives which are in the nature of public service and are of a charitable, religious or political nature; or (iv) Any person or body of persons associated with press or media; 6. Section 65(25a) was amended and renumbered as Section 65(25aa) by the Finance Act, 2011 dated 8.4.2011. Post the amendment, the provision reads: club or association means any person or body of persons providing services, facilities or advantages, primarily to its members, for a subscription or any other amount, but doe