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Demand of differential service tax - Provider of GTA service - Whether the recipient of services were liable to pay ST on reverse charge basis (RCM) - all the service recipient are body corporate, dealer of excisable goods, registered factory, a partnership firm which are covered under exemption notification, whereby the service recipient is liable to pay service tax. Therefore, the assumption of the adjudicating authority is absolutely incorrect without any basis. - Demand set aside - AT