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    <title>2024 (3) TMI 455 - CESTAT KOLKATA</title>
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    <description>Supply of tankers and bowsers for crude oil transportation was held to be a taxable supply of tangible goods service because possession and effective control did not pass to the user; the supplier retained repair, maintenance, fuel, crew and compliance obligations, so the arrangement was not a deemed sale by transfer of right to use goods. The demand for the period from 01.07.2012 was unsustainable because it was founded on a charging provision not applicable under the negative list regime then in force. Extended limitation and penalty were also not invokable, as the transactions were treated as deemed sales in a bona fide manner and there was no suppression with intent to evade tax. Consequential interest and penalty were set aside.</description>
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