Coal Transport to Rail Sidings Classified as Goods Transport Agency Service u/s 65(105)(zzp), Not Mining Service.

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....Classification of services - the activity undertaken i.e. transportation of coal from pit–heads to the railway sidings within the mining areas is more appropriately classifiable u/s 65(105) (zzp) i.e. GTA service and it is not involved in the service in relation to the “mining of mineral”, oil or gas”.....