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2025 (8) TMI 1471

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....t, Ranjit Singh is proprietor of two firms viz., M/s TCM Associates and M/s Shree Construction and TDS under 26AS for 2014-15 has been deducted under his PAN No. AJLPS6150K which is common for both the firms. He has obtained VAT Registration in the name of M/s Shree Constructions, 5-Meera Bai Marg, Lucknow having TIN No.09950002048 and has obtained Service Tax Registration No. AJPLS6150KSD001 in the name of his other firm M/s TCM Associates which is Appellant in the case. Both these firms are proprietory concerns. M/s Shree Constructions is engaged in construction related activities such as „Works Contract Services‟ whereas M/s TCM Associates is engaged in „Repair and Maintenance Services‟ in respect of air condition....

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....d Consultant appearing on behalf of the Appellant submitted that the above amount of Rs.1,94,13,245/- will not be liable to be included in the taxable value for assessment of tax liability as the same pertains to M/s Shree Constructions and therefore the Tax would be liable to be assessed on taxable value of Rs.35,49,871/-(2,29,63,116 -1,94,13,245) which pertains to the Appellant. It may be seen that the Appellant has rightly declared his taxable value i.e. Rs.35,42,293/- in his ST-3 Return. There is only marginal difference of Rs.7,578/- (35,49,871 - 35,42,293) which may be due to some other attendant factors. The above grounds were also taken in the appeal and also explained before the Commissioner (Appeals). However, he did not consider ....