Service tax quantification turned on verification of freight records and exemption notification conditions before reassessment.

Service tax quantification depended on verification of freight documents and freight accounts, because the dispute concerned correct computation rather than the existence of the levy. The records had to be examined to determine whether the conditions and thresholds in the relevant exemption notifications were satisfied. If those requirements were met, the appellant would be entitled to the exemption benefit. The matter was therefore remanded for fresh adjudication after verification of the records and grant of hearing.

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Issues: Whether the service tax liability required fresh verification of freight documents for proper quantification and for determining entitlement to the benefit of the relevant exemption notifications.

Analysis: The disputed liability was not on the existence of the levy but on the correctness of quantification. Since the freight documents and freight accounts had not been verified, it was necessary to examine the records to ascertain whether the thresholds in the exemption notifications were satisfied. If the conditions of the notifications were met, the appellant was entitled to their benefit. Fresh adjudication was therefore required after giving an opportunity of hearing.

Conclusion: The matter was remanded to the original adjudicating authority to redetermine the service tax liability after verifying the records and considering the exemption notifications.

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