The CESTAT held that the appellant's transportation of goods by...

The CESTAT held that the appellant's transportation of goods by road does not attract service tax under Section 66D(p)(i) of the Finance Act, 1994, as they are neither a goods transportation agency nor a courier agency. The charges reimbursed for freight and insurance, incurred on behalf of customers, do not constitute taxable service. The invocation of the extended limitation period under Section 73(1) was rejected since the demand was based solely on disclosed financial records without any concealment or suppression. Consequently, the penalty under Section 78 was also set aside because its imposition depends on the extended limitation period's applicability. The Tribunal allowed the appeal, quashing the service tax demand, interest, and penalty, affirming that no service tax liability arose on the freight income and related charges reimbursed by the appellant.