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of Adjustment of Advance tax paid (service portion) - Apportionment of advance received towards supply of goods and supply of services - Rule 6(4A) and 6(4B) of the Service Tax Rules, 1994 - There is no rationale in contention of the department that the whole of 2nd installment of Rs. 40.25 crore should be considered towards service portion and is liable to service tax @10.3%. Demand is merely presumptive with no corroborative evidence and cannot be sustained. - AT
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