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    <title>2026 (4) TMI 1588 - CESTAT NEW DELHI</title>
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    <description>Supplying buses with drivers and maintenance to a transport corporation was treated as a transport arrangement, not Rent-a-Cab Service, because route control and ticket issuance remained with the corporation and effective operational control did not pass to the recipient. The Tribunal also noted that the legal position was unsettled during the relevant period and accepted the supplier&#039;s bona fide belief of non-taxability, so the extended limitation period was not available and the consequential penalties could not survive. The demand therefore failed on merits and on limitation, and the assessee obtained full relief.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790519</link>
      <description>Supplying buses with drivers and maintenance to a transport corporation was treated as a transport arrangement, not Rent-a-Cab Service, because route control and ticket issuance remained with the corporation and effective operational control did not pass to the recipient. The Tribunal also noted that the legal position was unsettled during the relevant period and accepted the supplier&#039;s bona fide belief of non-taxability, so the extended limitation period was not available and the consequential penalties could not survive. The demand therefore failed on merits and on limitation, and the assessee obtained full relief.</description>
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