TMI Blog2013 (12) TMI 863X X X X Extracts X X X X X X X X Extracts X X X X ..... in accounting where it will be possible to conduct audit on the basis of samples chosen on scientific basis to work out the liability across the whole organization based on such samples. We consider that it would be appropriate to direct the appellant to get such audit done and based on that if any liability arises, the same can be worked out across the organization and total liability arrived at - Decided against assessee. - Appeal No.ST/1734/2012 - - - Dated:- 27-6-2013 - SHRI B.S.V. MURTHY AND DR. D.M. MISRA, JJ. For the Appellant : Mr. S. Ananthan, Chartered Accountant For the Respondent : Mr. R.K. Singla, Commissioner(AR) JUDGEMENT Order Per: B.S.V. Murthy; Demand of service tax of Rs.10,18,29,477/- has bee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee to ensure that tax has been paid correctly if some income cannot be explained, it means self-assessment is incomplete. However, there is a need to find a reasonable process by which the dispute can be settled. At this juncture, we take note of the observations of the Commissioner in para 27.3.11.4.2, which is as under:- 27.3.11.4.2. Though from the nature of income it appears that the income cannot be treated as income towards any taxable service/value, M/s. Canara Bank have neither submitted any bills, challans, any other documents substantiating their claim that these receipts pertained to various items such as disposal of furniture, sale of old and unwanted study materials/records, incentive received from airlines f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... understand and appreciate that it will not be possible to go into each and every receipt/transaction of every rupee to arrive at the conclusion whether it was as a result of rendering taxable service or not in respect of each and every receipt/transaction of more than 2500 branches of the appellant. There are procedures in accounting where it will be possible to conduct audit on the basis of samples chosen on scientific basis to work out the liability across the whole organization based on such samples. We consider that it would be appropriate to direct the appellant to get such audit done and based on that if any liability arises, the same can be worked out across the organization and total liability arrived at. Both sides agree that this ..... X X X X Extracts X X X X X X X X Extracts X X X X
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