Best-judgment assessment of security agency service value must...

Best-judgment assessment of security agency service value must rest on actual, verifiable records and a rational nexus to services and consideration, rather than assumed growth or earlier peak turnover; unsupported demands require fresh determination. Receipts must be examined transaction-wise to exclude legally exempt, non-taxable and genuine reimbursable amounts, subject after amendment to pure-agent conditions. Export and SEZ exemptions require examination of transactional evidence, not rejection solely for missing documents. CENVAT credit cannot be denied merely because salary expenditure predominates; admissibility requires record-based verification. Extended limitation requires deliberate evasion and is unavailable for disclosed audited records, subject in any event to the five-year outer limit. Parallel proceedings must not produce duplicate demand or recovery; remand must exclude transactions already determined.