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2011 (11) TMI 414 - AT - Service TaxDemand - CCE found that the ST-3 returns submitted by BSNL, Banda UP (East) did not include the value of GSM services rendered in Banda during the period Oct., 2003 to Sep., 2008 and was prima facie of the view that Service tax on such services was not paid - Appellants submit that for services rendered through land lines each Secondary Switching Area (SSA) of the company was registered for payment of service tax and they were paying service tax for each SSA in the Commissionerate where the SSA was located - It is not clear from the SCN or from the impugned order whether the gross value, for which impugned Service tax has been demanded, was billed from Banda Office and collections accounted by Banda Office - the registration certificate dated 5-9-2006 does not have a list of premises covered by the registration. There is also an argument that centralized registration to include the premises of Banda office was taken only from 10-12-2008 - It is not clear whether the issue being dealt with in the impugned order is one of procedural violations or a matter of revenue loss which is a substantive matter - Appeal is allowed by way of remand
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