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    <title>2026 (3) TMI 1528 - CESTAT ALLAHABAD</title>
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    <description>Transportation of goods by own trucks without issuance of consignment notes was held outside the taxable Goods Transport Agency category, so those receipts were not liable to service tax; consignments covered by goods receipts remained liable, if at all, under reverse charge under the applicable notification. The extended period of limitation could not be invoked for the demand because the notice was issued beyond five years for part of the period and the record showed no positive evidence of fraud, suppression of facts or intent to evade tax. A notice based only on third-party income-tax data, without independent verification and pre-show cause consultation, was treated as procedurally infirm. Interest and penalty fell with the unsustainable tax demand.</description>
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