The Bench remanded the matter to the adjudicating authority, directing that a fresh hearing be granted subject to costs.

The Tribunal observed that revenue has compared the figures reflected in the ST-3 returns and figures reflected in Form 26AS statement and raised the demand without further examining the reasons for the difference in the two statements.

The dispute arose from a lease transaction in which HDFC Bank sought refund of a security deposit after terminating the tenancy for occupying a commercial premises.