The purchasing dealer cannot be asked to do the impossible, that is, to identify a selling dealer who will not deposit with the Government the tax collected by him from purchasing dealers, and avoid transacting with such selling dealers, said the court.

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 issues put forth by the petitioner had already been decided through earlier civil proceedings.