https://www.taxtmi.com/caselaws?id=786630 Service tax demand cannot be sustained merely because Form 26AS and ST-3 returns show differences; the department must independently establish that the receipts are consideration for taxable services. Where the assessee offers a reconciliation explaining that part of the Form 26AS entries consists of bank interest under Section 194A of the Income-tax Act, 1961, and the remaining receipts are otherwise explained and accepted on record, the discrepancy alone does not justify tax liability. In the absence of contrary evidence or independent verification linking the amounts to taxable services, the differential demand is not maintainable. en-us Tue, 26 Aug 2025 00:00:00 +0530 Mon, 16 Feb 2026 12:20:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786630 Service tax demand cannot be sustained merely because Form 26AS and ST-3 returns show differences; the department must independently establish that the receipts are consideration for taxable services. Where the assessee offers a reconciliation explaining that part of the Form 26AS entries consists of bank interest under Section 194A of the Income-tax Act, 1961, and the remaining receipts are otherwise explained and accepted on record, the discrepancy alone does not justify tax liability. In the absence of contrary evidence or independent verification linking the amounts to taxable services, the differential demand is not maintainable. Case-Laws Service Tax Tue, 26 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786630