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4.2. In support of their above contentions, the appellant relied on the following decisions:

i. Firm Foundations & Housing Pvt. Ltd. [2018 (4) TMI 613];

ii. New Era Travel & Cargo Agencies [2024 (5) TMI 1520 (LB)];

iii. ITC Ltd., Coimbatore, [2025 (6) TMI 1967 (Chennai)];

iv. Forum Projects Pvt. Ltd., [2025 (1) TMI 1262];

v. UltraTech Cement Ltd. [2025 (3) TMI 971];

vi. Sen Brothers [2024 (8) TMI 1404];

vii. Go Bindas Entertainment [2019 (5) TMI 1487 (All.)];

5.1. In support of their contentions, the appellant places reliance on the following decisions:

i. T V. Purni Ads Pvt. Ltd. [2010 (4) TMI 186 (CESTAT-

Ahmd.)];

ii. V.K. Industries v. CGST, Dehradun [2025 (8) TMI 609 (CESTAT-All.)];

iii. Forum Projects [2025 (1) TMI 1262];

iv. Sen Brothers [2024 (8) TMI 1404].

5.2. Accordingly, it is contended by the appellant that the demand confirmed on the above count also cannot be sustained.

6. In view of the above submissions, the appellant prayed for setting aside the entire demand of service tax of Rs.1,59,49,183/- confirmed in the impugned order, along with interest and penalties thereon.

10.1. Further, it is pertinent to mention that Courts and Tribunals have consistently quashed demands confirmed solely on the basis of Profit and Loss Account, Ledger and ST-3 comparisons without correlation to taxable services.

10.2. In the case of Forum Projects Pvt. Ltd. [2025 (1) TMI 1262], this Tribunal has observed as under:

"10. Regarding the demand of service tax of Rs.88,051/-, we observe that these demands have been raised on the differential value of Profit & Loss Account and ST-3 returns. The appellant submitted that the Profit & Loss Account is prepared on accrual basis whereas Service Tax is payable on receipt basis and thus, there is a difference between the Appeal No.: ST/76716/2016-DB values declared in the ST-3 and Profit and Loss Account. We observe that the ld. adjudicating authority has not given any finding regarding the liability of service tax on the differential value. It is the settled position of law that demand of Service Tax cannot be confirmed merely on the ground that there is a difference in the value of Profit & Loss Account and ST-3 returns. We observe that this issue is covered by the decision of Tribunal, Kolkata in the case of Balajee Machinery v. Commissioner of C.G.S.T. & Excise, Patna-II [2022 (66) G.S.T.L. 440 (Tri. - Kol.)]. The relevant part of the said decision is reproduced below: -