Documentary proof governs exclusion of reimbursements from taxable value, and incomplete records justify remand for fresh verification.

Reimbursement claims can be excluded from taxable value only when the assessee produces satisfactory documentary proof that the expenditure was actually incurred on behalf of clients and recovered on an actual basis. Receipts alleged to fall outside the taxable activity also require verification, and where the record before the original authority is incomplete, the order cannot be sustained without examining the missing material. The impugned order was set aside and the matter was remanded for fresh consideration after giving the appellant an opportunity to produce the required documents.

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Issues: Whether the amounts claimed as reimbursement and other receipts were includible in the taxable value of service tax and the matter required fresh verification.

Analysis: Exclusion of reimbursed expenditure is permissible only when the assessee establishes, with supporting documents, that the amounts were actually incurred on behalf of clients and recovered on actual basis. The receipts claimed to be outside the taxable activity also required scrutiny, but the record before the original authority was incomplete. As the necessary documents were not fully examined, the impugned order could not be sustained without affording an opportunity for proper verification.

Conclusion: The impugned order was set aside and the matter was remanded to the original authority for fresh consideration after granting the appellant an opportunity to produce the required documents.

Ratio Decidendi: Reimbursement claims can be excluded from taxable value only on satisfactory documentary proof of actual incurrence and recovery, and where the factual record is incomplete, remand for fresh verification is appropriate.

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