The appellant, Commissioner of GST and Central Excise, filed appeals challenging the orders of the tribunal relating to the levy of service tax on certain transactions undertaken by M/s Citibank N.A. under the Finance Act, 1994. The issue involved the classification and taxability of banking and financial services, particularly concerning whether certain inter-branch and inter-company financial transactions were liable to service tax. The department contended that the services provided by Citibank fell within the ambit of taxable services under Section 65(105) of the Finance Act, whereas the respondent maintained that the activities did not amount to a taxable service and were exempted under the relevant provisions.

The Supreme Court heard the parties and disposed of the appeals in terms of its non-reportable judgment. The Court upheld the reasoning of the lower forum, thereby settling the dispute in accordance with the findings of the tribunal. All pending applications, including stay applications, were also disposed of as a consequence of the main decision.