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    <title>2024 (8) TMI 717 - CESTAT KOLKATA</title>
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    <description>Classification of services dispute examined whether leasing railway rakes to Indian Railways amounted to a supply of tangible goods service; tribunal found the appellant lacked effective control and possession once rakes were handed to Railways, so clients received transportation of goods by rail service and no supply of tangible goods service was rendered. The agreement showed rakes were allotted from a common pool and not retained by the appellant, supporting this conclusion. Separately, demands relating to 200809 and 200910 were time-barred as the show cause notice issued in 2012 exceeded the normal limitation period, so the demand was set aside.</description>
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      <description>Classification of services dispute examined whether leasing railway rakes to Indian Railways amounted to a supply of tangible goods service; tribunal found the appellant lacked effective control and possession once rakes were handed to Railways, so clients received transportation of goods by rail service and no supply of tangible goods service was rendered. The agreement showed rakes were allotted from a common pool and not retained by the appellant, supporting this conclusion. Separately, demands relating to 200809 and 200910 were time-barred as the show cause notice issued in 2012 exceeded the normal limitation period, so the demand was set aside.</description>
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