Reimbursements of wages paid to field consultants were held not...

Reimbursements of wages paid to field consultants were held not includible in taxable value where they were mere pass-through amounts and tax had already been discharged on the service charge; the related demand was set aside. Diesel supplied under separate contracts was treated as a goods transaction, not part of the service value, so service tax on that component was unsustainable. Supply of soil by unit-based work order was not site formation service because it did not involve preparatory site activity. A demand based only on mismatch between ST-3 returns and balance sheet failed for want of evidence, and extended limitation was rejected as suppression was not proved. The demand, interest and penalties were set aside.

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