The bench criticized the revenue’s mechanical reliance on information from the Central Intelligence Unit without independent verification. It was also observed that the report relied upon was never supplied to the assessee, violating principles of natural justice.

The tribunal noted that the CIT(A) had not verified whether the service tax was actually received or routed through accounts and had not obtained a remand report from the AO

If the Revenue satisfies the court that the case falls strictly within the provisions of the law, the subject can be taxed, said the apex court.