Jurisdictional objection and reimbursable expenses claims failed where factual findings were supported by the record and no perversity was shown.

A belated jurisdictional objection raised for the first time before the Tribunal was rejected because it was unsupported by material showing that the notice or adjudication was issued by an unauthorised officer, and the record reflected acquiescence in the process. A separate challenge to taxability of alleged reimbursable expenses also failed because the assessee did not prove that the recoveries were confined to statutory levies paid on behalf of clients; the findings showed excess collections and no reliable evidence of exclusion from service tax. The analysis treats both issues as factual and record-based, with no perversity or substantial question of law arising.

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Issues: (i) Whether the belated challenge to the jurisdiction of the adjudicating authority could be entertained; (ii) Whether the amounts claimed as reimbursable expenses were proved to be outside the service tax liability.

Issue (i): Whether the belated challenge to the jurisdiction of the adjudicating authority could be entertained.

Analysis: The jurisdictional objection was raised for the first time before the Tribunal and was supported by no material showing that the notice and adjudication were in fact by an unauthorised officer. The record showed acquiescence in the adjudicatory process, and the objection depended upon factual assertions that had not been established.

Conclusion: The belated jurisdictional challenge was rightly rejected and did not give rise to any substantial question of law.

Issue (ii): Whether the amounts claimed as reimbursable expenses were proved to be outside the service tax liability.

Analysis: The Tribunal found that the assessee failed to prove that the recoveries represented only statutory levies paid on behalf of clients. The material showed collections in excess of the alleged statutory dues, and there was no reliable proof of reimbursable expenditure excluding the amounts from tax.

Conclusion: The claim that the amounts were merely reimbursable expenses was rejected, and the factual findings on tax liability were upheld.

Final Conclusion: The appeal failed because the Tribunal's findings were factual, were supported by the record, and did not suffer from perversity or any legal error warranting interference.

Ratio Decidendi: A belated jurisdictional objection unsupported by material, and a challenge to factual findings on tax liability that do not disclose perversity, do not raise a substantial question of law.

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