D.N. Panda, Judicial Member. ‑ Ld. Counsel submits that at the initial stage of introduction of law for levy of service tax under Finance Act, 1994 in respect of security services, there were several confusions about the gross value of the service to become measure of value for payment of service tax. Only because of the confusion there was a discrepancy between the return and the profit and loss account. While Revenue's claim is that entire value of payments received from the consumer of service shall be taxable, the appellant pleads bona fide belief that statutory payments like ESI, PF etc. received, not being consideration for the services, shall not be taxable. Similarly, they plead that the profit earned on the activity shall not be taxable, so also certain other expenses. According to the appellant with the bona fide conception the appellant submitted the return and disclosed the receipts. There was no suppression of fact made by them in respect of the payment received, as it was furnished to the authorities in the course of adjudication. Only because the discrepancy was noticed by the department by comparing ST-3 return with the profit and loss account, the adjudication