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    <title>2026 (5) TMI 579 - CESTAT NEW DELHI</title>
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    <description>Hiring buses to transport employees and school children on fixed routes for a per-day consideration was treated as transport of passengers in a contract carriage under the Motor Vehicles Act, 1988. On that basis, the activity fell within the applicable exemption for transport of passengers by contract carriage, and service tax was not payable under reverse charge mechanism for the period covered by the notifications and retrospective validation. The later amendment limiting the exemption to non-air-conditioned vehicles did not alter the position for the relevant period, and the demand with consequential penalty could not be sustained.</description>
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