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    <title>2026 (4) TMI 299 - CESTAT KOLKATA</title>
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    <description>Services performed directly for clients within a port area were treated as stevedoring and movement of export cargo, not as Port Service merely because the provider was authorised to operate inside the port. The activity was classified as Cargo Handling Service, and the exemption available for export cargo during the relevant period applied, so the service tax demand, interest and penalties could not be sustained on merits. The subsequent show cause notice was also held to be time-barred because the Department had already audited the matter and had the relevant facts and explanation, making the extended limitation inapplicable on the same issue.</description>
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