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    <title>2025 (11) TMI 196 - CESTAT ALLAHABAD</title>
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    <description>Hiring of tankers to a goods transport agency was treated as a lease for use, but the arrangement did not transfer effective possession and control so as to constitute a taxable transfer of right to use tangible goods. The applicable service tax exemption notifications therefore covered the supply, and no service tax was payable on the transaction. On limitation, the demand could not rely on the extended period because audit had already noticed the issue and the show cause notice was issued after more than two years without adequate justification. The impugned order was set aside.</description>
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      <description>Hiring of tankers to a goods transport agency was treated as a lease for use, but the arrangement did not transfer effective possession and control so as to constitute a taxable transfer of right to use tangible goods. The applicable service tax exemption notifications therefore covered the supply, and no service tax was payable on the transaction. On limitation, the demand could not rely on the extended period because audit had already noticed the issue and the show cause notice was issued after more than two years without adequate justification. The impugned order was set aside.</description>
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