Service Tax Demand Based Only on ITR/ST-3 Mismatch Unsustainable: CESTAT Rules Revenue Must Establish Taxable Value Before Levy

This article covers a CESTAT ruling that a service-tax demand cannot be sustained merely on the basis of a mismatch between ITR and ST-3 returns; the authorities must first assess and establish the taxable value. The decision strengthens taxpayer protection against arbitrary tax demands and emphasises requirement of substance over procedural mismatch.