Transport arrangement for sold goods was not business support service, so the service tax demand failed.

Arranging transportation of sold goods through truck owners or other transporters, without issuing consignment notes or lorry receipts and without any separate logistics or distribution arrangement, was treated as mere transport coordination rather than a taxable business support service. The charges collected over actual freight did not, by themselves, establish an independent service element. Applying the cited precedent, the tribunal held that delivery-related transport arranged for sale of goods does not become business support service in the absence of a separate service contract or distinct support activity. On those facts, the service tax demand was not sustainable.

---

---

Issues: Whether the activity of arranging transportation of goods for buyers, without any separate service contract or logistics support, and collecting an amount over the actual freight paid, amounted to taxable business support service and sustained a service tax demand.

Analysis: The dispute turned on the true character of the activity undertaken by the assessee. The record showed that the assessee only arranged transportation of sold goods through truck owners or other transporters, without issuing consignment notes or lorry receipts and without undertaking any independent logistics or distribution service. The charges recovered from customers were linked to arranging transport and did not establish a separate service element. The reasoning in the cited precedent was applied, namely that delivery-related transportation arranged for sale of goods, in the absence of a separate service arrangement, does not create a taxable business support service. On the facts, no specific case was made out that the assessee was providing any service other than organising transportation of goods.

Conclusion: The activity was not business support service and the service tax demand was not sustainable. The assessee succeeded and the revenue's challenge failed.

---