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CESTAT ruled on interpretation of "month" under Rule 6(4A) of Service Tax Rules, 1994 regarding adjustment of excess service tax payments. Applying Section 13 of General Clauses Act 1897, the Tribunal held that singular words include plural meaning, allowing adjustment of excess tax in multiple subsequent months/quarters. The strict interpretation limiting adjustment to single month would unfairly cause unused excess amounts to lapse. Following established judicial precedents including SC rulings on statutory interpretation, CESTAT concluded appellant's adjustments across different months were valid and compliant with Rule 6(4A). Appeal allowed and impugned order set aside.
CESTAT ruled on interpretation of "month" under Rule 6(4A) of Service Tax Rules, 1994 regarding adjustment of excess service tax payments. Applying Section 13 of General Clauses Act 1897, the Tribunal held that singular words include plural meaning, allowing adjustment of excess tax in multiple subsequent months/quarters. The strict interpretation limiting adjustment to single month would unfairly cause unused excess amounts to lapse. Following established judicial precedents including SC rulings on statutory interpretation, CESTAT concluded appellant's adjustments across different months were valid and compliant with Rule 6(4A). Appeal allowed and impugned order set aside.
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