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    <title>2024 (3) TMI 457 - CESTAT AHMEDABAD</title>
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    <description>Sizing, breaking, loading and transporting already mined limestone under a work order did not amount to Mining Service because the provider undertook no mining activity and the principal work was transportation, making the service tax demand unsustainable on merits. The extended limitation period also could not be invoked because the activity was within departmental knowledge, the recipient was paying service tax under reverse charge, and audits had been conducted without objection, so suppression of facts was not established. The demand was therefore held to fail both on classification and limitation, with consequential relief granted.</description>
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      <description>Sizing, breaking, loading and transporting already mined limestone under a work order did not amount to Mining Service because the provider undertook no mining activity and the principal work was transportation, making the service tax demand unsustainable on merits. The extended limitation period also could not be invoked because the activity was within departmental knowledge, the recipient was paying service tax under reverse charge, and audits had been conducted without objection, so suppression of facts was not established. The demand was therefore held to fail both on classification and limitation, with consequential relief granted.</description>
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