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of AAR ruled that transportation services provided by subcontractor X to principal GTA are not exempt under Entry 18 of Notification 12/2017-CT(Rate). Since X does not issue consignment notes, a key requirement to qualify as GTA, their services constitute vehicle rental rather than goods transportation. The principal GTA maintains the direct transportation contract with consignors/consignees and issues consignment notes, while X merely provides vehicles. The services fall under Notification 11/2017-CT(Rate) as transport vehicle rental services and are therefore taxable. The exemption sought was denied as X's activities fall outside the scope of transportation services by a GTA.
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