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    <title>2023 (8) TMI 1234 - CESTAT AHMEDABAD</title>
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    <description>Exemption under Notification No. 30/2012-ST for goods transport agency services depends on verified satisfaction of the specified recipient-status conditions, and liability cannot be fastened on mere presumption. The record suggested that several service recipients were limited companies and partnership firms, yet the benefit was denied on an assumption that some recipients may have been proprietary concerns. The status of the recipients required proper verification before service tax liability could be confirmed, and exemption could not be refused without factual examination. The impugned order and demand were set aside, and the matter was remanded for fresh consideration on all issues.</description>
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      <description>Exemption under Notification No. 30/2012-ST for goods transport agency services depends on verified satisfaction of the specified recipient-status conditions, and liability cannot be fastened on mere presumption. The record suggested that several service recipients were limited companies and partnership firms, yet the benefit was denied on an assumption that some recipients may have been proprietary concerns. The status of the recipients required proper verification before service tax liability could be confirmed, and exemption could not be refused without factual examination. The impugned order and demand were set aside, and the matter was remanded for fresh consideration on all issues.</description>
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