Reverse charge on transportation services requires a reasoned finding; incomplete adjudication was set aside and remanded.

The adjudicating authority failed to return a finding on the petitioner's contention that the services were transportation services and that, if tax was payable, liability fell on the recipient under the reverse charge notification. Because the order-in-original noticed the plea and supporting documents but gave no reasons for rejecting the transport-services classification, the adjudication was incomplete. The Karnataka HC set aside the impugned order and remitted the matter for fresh consideration, keeping the petitioner's contentions open.

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Issues: Whether the adjudicating authority failed to consider the petitioner's contention that the services were transportation services and that the tax liability, if any, rested on the recipient under the applicable notification, warranting setting aside of the order and remand.

Analysis: The order-in-original referred to the petitioner's plea based on the notification governing reverse charge on transportation services and also noticed the documents produced, but it recorded no finding on that contention. The reason for rejecting the petitioner's case that the activity related to transportation of goods was also not disclosed. In these circumstances, the adjudication was found to be incomplete. The petitioner expressed readiness to appear again and substantiate the transactions with the existing documents.

Conclusion: The impugned order was set aside and the matter was remitted for fresh consideration, with the petitioner's contentions kept open.

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