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    <title>2026 (7) TMI 238 - CESTAT NEW DELHI</title>
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    <description>Extended limitation under service tax was held unavailable on reverse charge liability where the dispute was revenue neutral and no intent to evade was shown, so the earlier-period demand was set aside. Amounts booked for labour, repair and maintenance, and freight and cartage were not automatically classifiable as manpower supply, works contract, or goods transport agency service absent the legal ingredients of those taxable entries; the corresponding demands were set aside. The labour component required limited factual verification to determine whether one person collected receipts on behalf of multiple labourers and acted as manpower supplier. If tax became payable on that basis, refund would be available in cash under the transitional GST provision, and the matter was remanded only for that issue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794352</link>
      <description>Extended limitation under service tax was held unavailable on reverse charge liability where the dispute was revenue neutral and no intent to evade was shown, so the earlier-period demand was set aside. Amounts booked for labour, repair and maintenance, and freight and cartage were not automatically classifiable as manpower supply, works contract, or goods transport agency service absent the legal ingredients of those taxable entries; the corresponding demands were set aside. The labour component required limited factual verification to determine whether one person collected receipts on behalf of multiple labourers and acted as manpower supplier. If tax became payable on that basis, refund would be available in cash under the transitional GST provision, and the matter was remanded only for that issue.</description>
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