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.

Members are advised to provide accurate information such as the ticket number, date of submission, a brief summary of the issue, and the current status of the ticket to facilitate timely escalation.