Cargo Handling in Container Freight Stations (CFS) Not Incidental to Storage; Primary Role is Import/Export Handling.

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....Levy of Service Tax - Cargo Handling Services - there are no merit in the argument of Revenue that the activity of Cargo Handling in the Container Freight Station is incidental to the Storage and Warehousing activity. From the discussion it is apparent that storage in the container freight station is only incidental to the cargo handling activity. The main purpose of the Container freight Stations is to handle cargo for the purpose of import or exports. The main purpose of the container Freight Stations is not Storage and Warehousing. In these circumstances, we do not find any merit in the order of Lower Authorities. - AT....