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8.3 It is the Noticee's argument that they have reflected
the taxable value and tax payable by them in the service
tax returns filed under the PAN- ADSPN7217K of Shri K.
Surendran Nair and that this is human error which should
be condoned. As noted earlier, the identity of a partnership
firm and that of an individual are separate and distinct;
and the argument of human error here does not hold good
particularly when the individual concerned is also engaged
in providing taxable services on his own. I therefore,
unable to convince myself to accept such argument of
condonable human error in the facts and circumstances of
this case."