Consignment note requirement excludes individual truck transport from GTA service tax, leaving the recipient outside liability.

Transportation of sugarcane by individual truck operators without consignment notes does not fall within the statutory meaning of Goods Transport Agency service. The taxable GTA category applies only where goods are transported by road by a commercial concern issuing a consignment note containing the required particulars; mere bills, GRs, challans or similar documents are necessary to satisfy that description, and transporters' bills alone are insufficient. As the required consignment note was absent, the activity was not taxable as GTA service and no service tax liability arose on the recipient.

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Issues: Whether transportation of sugarcane by individual truck operators without issuance of consignment note amounts to service provided by a Goods Transport Agency so as to attract service tax under the GTA category.

Analysis: The dispute turned on the statutory meaning of Goods Transport Agency and the requirement of a consignment note. The relevant provisions define the taxable GTA service with reference to transport of goods by road by a commercial concern issuing a consignment note, and the prescribed rules contemplate a document containing specified particulars. Mere transportation of goods by road, without consignment notes, GRs, challans or comparable documents, does not answer that statutory description. The transporter's bills cannot be treated as consignment notes, because they do not establish the liability and documentary features required by the rule.

Conclusion: Transportation by individual truck operators without consignment notes is not GTA service, and no service tax liability arises on the recipient. The Revenue's appeal fails.

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