Transparent recomputation of tax demand under an exemption notification requires clear reasons, justifying a further remand.

Where a remand requires reworking a service tax demand after extending the benefit of Notification No. 06/2005, the adjudicating authority must clearly explain how the revised liability is computed. The revised order reduced the demand, but the remaining liability was not supported by transparent reasoning, so the exemption benefit was not shown to have been fully worked out. As the calculation lacked adequate reasons, a further limited remand was warranted for fresh consideration and a reasoned order within the stipulated time. The impugned order was set aside to that extent.

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Issues: (i) Whether the adjudicating authority had properly reworked the service tax demand by extending the benefit of Notification No. 06/2005 dated 01.03.2005. (ii) Whether the matter required a fresh remand for recording proper reasons for the revised demand calculation.

Issue (i): Whether the adjudicating authority had properly reworked the service tax demand by extending the benefit of Notification No. 06/2005 dated 01.03.2005.

Analysis: The earlier remand required the demand to be reworked after extending the benefit of the exemption notification. The revised order reduced the demand, but the basis and reasoning for the remaining liability were not clearly explained. The calculation was therefore not shown to fully and transparently reflect the benefit directed to be granted.

Conclusion: The benefit of the exemption notification was not adequately and clearly worked out in the impugned order.

Issue (ii): Whether the matter required a fresh remand for recording proper reasons for the revised demand calculation.

Analysis: Since the revised computation did not disclose the reasoning for arriving at the remaining demand, further scrutiny by the adjudicating authority was necessary. To avoid continued uncertainty and delay, a limited remand with a time-bound direction was warranted so that the calculation and liability could be explained with reasons.

Conclusion: The matter was remanded again for fresh decision with specific reasons to be recorded within the stipulated time.

Final Conclusion: The appeal succeeded to the extent that the impugned order was set aside for fresh consideration, and the adjudicating authority was directed to pass a reasoned order within two months.

Ratio Decidendi: Where a remand direction requires recalculation of tax liability by extending an exemption, the adjudicating authority must record clear reasons showing how the revised demand is computed; absence of such reasoning justifies a further remand.

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