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    <description>Liability under the goods transport agency category arises only when transport of goods by road is accompanied by issuance of a consignment note; absent that document, internal transport arrangements do not by themselves attract service tax. Services used for authorised operations in a Special Economic Zone remain exempt under the SEZ Act and Rules, which operate with overriding effect over inconsistent conditions. The demand was also beyond limitation because the department was already aware of the relevant facts and the extended period was not justified. Amounts already deposited were therefore refundable under the applicable refund mechanism.</description>
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