CESTAT partly allowed the appeal. The Tribunal held that a...

CESTAT partly allowed the appeal. The Tribunal held that a demand founded solely on comparison of Form 26AS/IT returns with ST-3 without further inquiry was unsustainable; amounts shown as reimbursements under contracts where the appellant acted as a "pure agent" on actuals are not includible in taxable consideration, so the demand on such reimbursements was set aside. Extended-period demands were time-barred and therefore quashed. Confirmed demands under "Legal Charges" paid under reverse-charge were set aside on merits and for time-bar, given evidence of consultants' tax payment and the likelihood of input-credit neutralization. However, a late-filing fee imposed on the appellant was upheld.