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    <title>2026 (6) TMI 955 - CESTAT KOLKATA</title>
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    <description>Equipment-hiring transactions were treated as a transfer of the right to use goods where the customer had possession, custody and effective control during the contract period, used the equipment to the exclusion of the owner, and bore the risk. On that basis, the activity fell within deemed sale under Article 366(29A) and within the VAT/CST domain, not service tax under supply of tangible goods service. Because VAT/CST had already been discharged, the service tax demand was held unsustainable and the related penalty was set aside.</description>
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