Transportation service, not cargo handling, where loading and unloading were merely incidental to short-distance iron ore movement.

Short-distance movement of iron ore with loading at the dump yard and automated unloading at the railway siding was treated as transportation, not cargo handling, because the loading and unloading were incidental to the movement of goods and the contract was essentially for transport. The absence of separately stated loading and unloading charges did not by itself convert the service into cargo handling, and the circular relied upon was held inapplicable on the facts. The service was therefore not taxable as cargo handling service and fell within transportation service.

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Issues: Whether short-distance movement of iron ore with incidental loading into tipping trucks and automated unloading at the railway siding was classifiable as cargo handling service or as transportation service.

Analysis: The demand was confined to local transportation or shifting charges for movement from the dump yard to the railway siding, with loading at the dump yard and unloading at the siding being only incidental to the transportation activity. The contract was essentially for transport of goods, and the absence of separately stated rates for loading and unloading did not convert the service into cargo handling. The circular relied upon was held inapplicable to the facts, and the appellant was not shown to be a cargo handling agent.

Conclusion: The service was not taxable as cargo handling service and was to be treated as transportation service.

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