Abatement under service tax notifications cannot be denied solely for account and invoice mismatch when raw material purchases are shown.

Abatement under Notification No. 15/2004-ST and Notification No. 1/2006-ST could not be denied merely because the purchase bills did not fully match the figures shown in the profit and loss account and balance sheet. The record showed that raw materials had in fact been purchased, and exact quantification was not treated as a condition for denying the benefit. On that basis, the assessee was held entitled to the abatement, and the demand was remanded for recalculation.

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Issues: Whether the assessee was entitled to abatement under Notification No. 15/2004-ST or Notification No. 1/2006-ST despite mismatch between the purchase bills and the figures reflected in the profit and loss account and balance sheet.

Analysis: The entitlement to abatement under the notifications did not depend on proof of purchase of raw material to the exact extent claimed. The record showed that some raw materials had been purchased, even if the exact quantum could not be precisely ascertained. Denial of the benefit merely because the figures in the accounts did not fully tally with the invoices was held to be improper. The assessee was therefore found entitled to the abatement under the applicable notification.

Conclusion: The assessee was entitled to the benefit of abatement under Notification No. 15/2004-ST or Notification No. 1/2006-ST, and the matter was remanded for recalculation of the demand.

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