The court acknowledged the submission of the e-way bills, tax invoices, bilties and transporter payment ledgers, none of which were found to be defective or fabricated.

The court held that Chennai Police are not liable to service tax on Bundobast services prior to 1 June 2012 as the services are sovereign functions.

The Court clarified that certificates at 1.5% should continue to be issued for future years unless the ITAT order is reversed or the Department brings fresh relevant material establishing a PE in India.