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    <title>2025 (8) TMI 1832 - CESTAT BANGALORE</title>
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    <description>Supplying excavators, bulldozers and tippers with operators on hire for mining-related work was held not to be site formation, excavation, earthmoving or mining service where the provider merely supplied machinery and the mining company retained control over operations. The arrangement was treated in substance as supply of tangible goods for use, so the taxing entries invoked could not be stretched to cover the hire transaction. The scope of &quot;in relation to&quot; was applied narrowly, requiring a direct or proximate nexus with the taxable entry, which was absent on these facts. The demand was therefore unsustainable and the assessee succeeded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469348</link>
      <description>Supplying excavators, bulldozers and tippers with operators on hire for mining-related work was held not to be site formation, excavation, earthmoving or mining service where the provider merely supplied machinery and the mining company retained control over operations. The arrangement was treated in substance as supply of tangible goods for use, so the taxing entries invoked could not be stretched to cover the hire transaction. The scope of &quot;in relation to&quot; was applied narrowly, requiring a direct or proximate nexus with the taxable entry, which was absent on these facts. The demand was therefore unsustainable and the assessee succeeded.</description>
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