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    <title>2026 (3) TMI 1533 - CESTAT CHANDIGARH</title>
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    <description>A transportation contract for tractors on a per-kilometre, job-specific basis was not taxable as Manpower Recruitment or Supply Agency Services because the contractor undertook delivery responsibilities and related compliances, and the recipient sought delivery of tractors rather than deployment of personnel. The service tax demand was therefore set aside. However, failure to obtain registration and file service tax returns was treated as an independent breach attracting penalty under the service tax law, so the penalty was upheld notwithstanding the annulment of the tax demand.</description>
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      <description>A transportation contract for tractors on a per-kilometre, job-specific basis was not taxable as Manpower Recruitment or Supply Agency Services because the contractor undertook delivery responsibilities and related compliances, and the recipient sought delivery of tractors rather than deployment of personnel. The service tax demand was therefore set aside. However, failure to obtain registration and file service tax returns was treated as an independent breach attracting penalty under the service tax law, so the penalty was upheld notwithstanding the annulment of the tax demand.</description>
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