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    <title>2026 (2) TMI 906 - CESTAT BANGALORE</title>
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    <description>Whether service tax under the reverse charge mechanism applied to payments to Goods Transport Agencies and whether the demand was time barred were the central issues. The analysis records that payments to individual truck owners were evidenced and excluded, while payments to goods transport agencies lacked rebuttal evidence of agency services. However, because ledgers were maintained, audited and there was no finding of suppression with intent to evade tax, invocation of the extended period of limitation was unsustainable. Operatively, liability on payments to GTAs was not established by rebuttal and the confirmed demand was set aside as barred by limitation in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=786758</link>
      <description>Whether service tax under the reverse charge mechanism applied to payments to Goods Transport Agencies and whether the demand was time barred were the central issues. The analysis records that payments to individual truck owners were evidenced and excluded, while payments to goods transport agencies lacked rebuttal evidence of agency services. However, because ledgers were maintained, audited and there was no finding of suppression with intent to evade tax, invocation of the extended period of limitation was unsustainable. Operatively, liability on payments to GTAs was not established by rebuttal and the confirmed demand was set aside as barred by limitation in favour of the assessee.</description>
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