Unquantified and time-barred service tax notices for goods transport agency services cannot sustain demand proceedings.

Service tax demands for goods transport agency services require a clear, quantified show-cause notice; a vague or unquantified notice cannot validly support confirmation of demand. The text also notes that a notice issued beyond the permissible limitation period is barred and cannot sustain proceedings. On these grounds, the demand proceedings were held unsustainable, the impugned orders were set aside, and the original dropping of the demand was restored.

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Issues: Whether the show-cause notices demanding service tax on goods transport agency services were sustainable in law, particularly on the grounds of want of quantification and limitation.

Analysis: The demand related to recipient liability for goods transport agency services during an earlier period. The record showed that the notices proceeded without proper quantification of the tax amount, although quantification is required before a demand can be confirmed. The Tribunal also accepted that the notices were issued beyond the permissible period and were therefore hit by limitation. In view of these defects, the demand proceedings could not be sustained.

Conclusion: The issue was decided in favour of the assessee. The impugned orders were set aside and the original adjudication dropping the demand was restored.

Ratio Decidendi: A demand of service tax cannot be sustained where the show-cause notice is vague, unquantified, and barred by limitation.

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