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    <title>2026 (8) TMI 520 - CESTAT NEW DELHI</title>
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    <description>Beneficiation and washing of coal constituted mining activity and were not taxable as Business Auxiliary Service before 1 June 2007. The later introduction of a separate taxable category for services related to mining, without any amendment to the Business Auxiliary Service definition, confirms that the earlier general category did not cover those activities for the pre-introduction period. Accordingly, a tax demand on coal beneficiation or washing under Business Auxiliary Service for that period was unsustainable. The stated principle is that a newly introduced specific taxable service cannot retrospectively bring an activity within an unchanged pre-existing general category.</description>
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      <link>https://www.taxtmi.com/caselaws?id=796647</link>
      <description>Beneficiation and washing of coal constituted mining activity and were not taxable as Business Auxiliary Service before 1 June 2007. The later introduction of a separate taxable category for services related to mining, without any amendment to the Business Auxiliary Service definition, confirms that the earlier general category did not cover those activities for the pre-introduction period. Accordingly, a tax demand on coal beneficiation or washing under Business Auxiliary Service for that period was unsustainable. The stated principle is that a newly introduced specific taxable service cannot retrospectively bring an activity within an unchanged pre-existing general category.</description>
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