https://www.taxtmi.com/caselaws?id=777160 Service tax demands cannot be computed by mechanically comparing VAT/WCT returns with ST-3 returns where the two levies operate on different bases; for the pre-30.06.2011 period, receipt-based taxation and supporting auditor reconciliations showed the differential levy was unsustainable. Best judgment assessment under Section 72 must be grounded in the material on record and a reasonable estimate; where the assessee produced relevant documents, figures and reconciliation, an arbitrary uplift of turnover to 150% of the prior year lacked evidentiary basis. The demand for 2012-13 was therefore unsustainable, and no further service tax liability could be fastened. en-us Thu, 21 Aug 2025 00:00:00 +0530 Tue, 26 Aug 2025 08:41:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777160 Service tax demands cannot be computed by mechanically comparing VAT/WCT returns with ST-3 returns where the two levies operate on different bases; for the pre-30.06.2011 period, receipt-based taxation and supporting auditor reconciliations showed the differential levy was unsustainable. Best judgment assessment under Section 72 must be grounded in the material on record and a reasonable estimate; where the assessee produced relevant documents, figures and reconciliation, an arbitrary uplift of turnover to 150% of the prior year lacked evidentiary basis. The demand for 2012-13 was therefore unsustainable, and no further service tax liability could be fastened. Case-Laws Service Tax Thu, 21 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777160