ORDER 1. Heard learned Counsel for the parties. 2. In this writ application, the petitioner has challenged the issuance of Annexure-10 I.e. the show-cause notice dated 13.12.2006 by the office of the Commissioner, Central Excise and Service Tax, Jamshedpur asking him to file a show-cause on the points raised in the show-cause notice. 3. What it appears that the petitioner, who is the manufacturer of machine and machine parts, falling under Chapter-84 and 85 of the first Schedule of the Central Excise Tariff Act, 1985, was registered as Service Tax Assessee and it was providing services under the categories of Consulting Engineers services, Commissioning and installation services, repairs and maintenance services, construction services and goods transport agencies services. He allegedly short paid Service Tax amounting to Rs. 12,63,86,088/- and Education Cess amounting to Rs. 17,81,737/-, totaling Rs. 1.2,81,67,825/- by suppressing the correct taxable value and thereby violated the provisions of Section 67 and 68 of the Chapter-V of the Finance-Act, 1994 read with Rule 6 of the Service Tax Rule, 1994. 4. It is alleged that the petitioner did not pay their Service Tax under the category of Consulting Engineers Services for the periods 2003-04 and 2004-05 in respect of Turn Key works contract. It is further alleged that the petitioner willfully suppressed correct taxable value with intent to evade payment of service tax under the category of consulting engineers services during 2003-04 and 2004-05. 5. Accordingly, the Commissioner, Central Excise, and-Service Tax, by issue of Annexure-10, asked the petitioner to show cause within 30 days on the points formulated in the said show cause notice which are reproduced hereinbelow: 1. Service tax short paid amounting to Rs. 12,63,86,088/-(Rupees twelve crore sixty three lakh eighty six thousand eighty eight only) and education cess amounting to Rs. 17,81,737/- (Rupees seventeen lakh eighty one thousand seven hundred thirty seven only) totaling to Rs. 12,81,67,825/-(Rupees twelve crate eighty one lakh sixty seven thousand eight hundred twenty five only) as per enclosed annexure-I & II should not be recovered from them under provisions of Section 73 of Finance Act, 1994 for contravention of Section 67 & 68 of the Finance Act, 1994. 2. A penalty should not be imposed and recovered from them under Section 78 of the Finance Act, 1994; 3. Interest should not be recovered from them under Section 75 of the Finance Act, 1994. 4. 2. A penalty should not be imposed and recovered from them under Section 78 of the Finance Act, 1994; 3. Interest should not be recovered from them under Section 75 of the Finance Act, 1994. 4. A separate penalty should not be imposed and recovered from them under Section 77 of the Finance Act, 1994. 6. It is submitted on behalf of the petitioner that the show-cause notice (Annexure-10) Issued under Section 73 of the Finance Act, 1994, is time barred; as it has been issued after expiry of one year i.e. on 13.12.2006 from the relevant date. 7. It is next contended that the contract referred in the show-cause notice are In fact turn key project for executing woks under an agreement and the work is indivisible in character and that the works contract cannot be vivisected and part of it subjected to tax under the Service Tax. It is submitted that no Service Tax is payable on works contract on turn key basis. 8. In support of such submissions, reliance has been placed in the case of Daelim Industrial Co. Ltd. v. Commissioner of C.Ex., Vadodara. 9. The respondents Revenue Department has filed a counter affidavit controverting the stand taken by the petitioner id the writ application. 10. We are of the view that the dispute raised by the petitioner that the work is indivisible in character and it cannot be vivisected and that the Service Tax is not payable on works contract on turn key basis, has to be decided and determined on taking several factual aspects of the matter by the concerned authority who has issued notice to show cause to the petitioner on consideration of facts. Presently, only a show-cause notice as contained in Annexure-10 has been issued by the respondent Revenue to the petitioner whereby he has been asked to explain by filing show-cause with relevant documents to enable the respondents to come to a conclusion on the points raised by them in the show-cause notice and therefore, it is not desirable for this Court in writ jurisdiction to interfere at this stage when the respondent authorities are yet to pass an appropriate order on consideration of facts. Therefore, we are not inclined to interfere at this stage. 11. Therefore, we are not inclined to interfere at this stage. 11. Accordingly, without expressing any opinion on the merits of the case of either of the parties, this application is being disposed of by directing the petitioner to submit his show-cause to the respondent Revenue pursuant to Annexure-10. The petitioner may raise all points raised in this Writ Petition before the authority concerned. The respondent Revenue, after consideration of the show-cause and/or after hearing the representative of the petitioner, if so required, shall pass an appropriate reasoned order dealing the points raised by the petitioner in accordance with law as. expeditiously as possible, preferably within a period of three months from the date of filing of show-cause by the petitioner. 12. With this observations and directions, this writ petition stands disposed of. Writ petition disposed of.