My client is issued with demand notice of Rs. 1,80,000 for non filing of service Tax Return for past 9 half year @ 20,000 per Half Year. He has not filed his Return as there were no transaction during this period. It is NIl return. So whom shall we address the Response Letter. Whether to address for Superintendent or Central Excise Officer to waive the Penalty? Who has the power to waive the Penalty for Non filing of Timely Service tax return?