Service Tax Demand Based Solely on ST-3 and Form 26AS Discrepancies Deemed Unjustified Without Further Investigation.

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....Demand of service tax - on differences in amount reflected in the ST-3 returns and Form 26AS - without examining reasons for said difference, whether the same was because of any exemption or abatement, it is not legal to presume that the entire differential amount was on account of consideration for providing services - SCN is not sustainable....