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    <title>2026 (4) TMI 517 - CESTAT KOLKATA</title>
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    <description>Where the contract&#039;s substance was transportation of coal, with incidental loading, unloading, supervision and liaison work, the activity did not amount to clearing and forwarding agent service under Section 65(25) of the Finance Act, 1994. The service required clearing operations and forwarding of goods at the instance of the principal, which were absent here; the activity was therefore properly classifiable as Goods Transport Agency service. Consistently with the distinction applied in Coal Handlers Pvt. Ltd., service tax liability rested on the recipient rather than the appellant, and the demand raised against the appellant was unsustainable.</description>
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    <pubDate>Mon, 09 Mar 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=789448</link>
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