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CESTAT allowed the appeal, setting aside service tax demands for 2014-15 and 2016-17. The tribunal found no evidence of trade discounts not being passed to customers and accepted the appellant's proportionate credit reversal under Rule 6(3)(i) of CCR. The extended period of limitation was deemed inapplicable due to absence of tax evasion, and mandatory penalties were consequently set aside. The key determination was that the appellant had correctly paid service tax on value addition and reversed credits appropriately, rendering the department's demands unsustainable.
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