Deduction for materials used in photography service upheld; invoice disclosure of inputs was not required under the notification and clarification.

Photography service providers were entitled to deduct the value of materials used and consumed in rendering the service where records of inputs were maintained. The Tribunal held that neither the notification nor the Board's clarification required such materials to be separately mentioned in customer invoices, so denial of the deduction on that ground was contrary to the governing clarification and could not stand. The disallowance made by the lower authorities was set aside.

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Issues: Whether the assessee providing photography service was entitled to deduct the value of materials used and consumed in the course of providing the service, and whether such benefit could be denied on the ground that the materials were not shown in the invoices issued to customers.

Analysis: The Tribunal noted that the assessee maintained records of the inputs used in photography and had relied on the relevant notification and the Board's clarification. It was held that neither the circular nor the notification required the inputs used in photography to be specifically mentioned in the invoices or bills issued to customers. The denial of deduction on the ground that the invoices did not indicate the materials used was therefore contrary to the Board's clarification and the notification.

Conclusion: The assessee was held entitled to deduct the value of material used in providing photography service, and the disallowance made by the lower authorities was set aside.

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