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    <title>2026 (8) TMI 400 - AUTHORITY FOR ADVANCE RULING, KARNATAKA</title>
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    <description>Loading railway-owned ballast into stationary railway wagons using JCB loaders is treated as an independent cargo-handling service, not a works contract or composite supply. A works contract requires specified activity relating to immovable property and transfer of property in goods, which was absent. Ballast supply was completed on delivery and transfer of ownership, while subsequent loading was separately instructed, priced and invoiced; the activities were not naturally bundled and no principal supply arose. As loading involved no transportation, wagon movement, shunting, towing or other railway operation, it is classified as cargo handling under SAC 996719 and taxable at 18%.</description>
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      <description>Loading railway-owned ballast into stationary railway wagons using JCB loaders is treated as an independent cargo-handling service, not a works contract or composite supply. A works contract requires specified activity relating to immovable property and transfer of property in goods, which was absent. Ballast supply was completed on delivery and transfer of ownership, while subsequent loading was separately instructed, priced and invoiced; the activities were not naturally bundled and no principal supply arose. As loading involved no transportation, wagon movement, shunting, towing or other railway operation, it is classified as cargo handling under SAC 996719 and taxable at 18%.</description>
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