Suppression Or Wilful Concealment Not Attributable To Assessee When Departmental Authorities Differ On Taxability Of Services: CESTAT

CESTAT held that suppression or willful concealment cannot be attributed when departmental authorities themselves differ on the taxability of services. The tribunal reasoned that if the tax authorities within the department have varying interpretations regarding whether a particular service is taxable or not, then the assessee cannot be accused of deliberately suppressing information or concealing facts with the intent to evade tax. This ruling provides relief to taxpayers in situations where taxability is genuinely ambiguous.