Transport Activities in Mining Aren't GTA or Mining Services; Transport Charges Excluded from Mining Service Valuation.

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....Classification of services - to be classified under GTA services or under mining services? - deployment of loaders, excavators, dozers for removal of overburden, waste ash, spillage, etc. and also loading of raw coal, clean coal, secondary coal, rejects and ash, etc. - when it has not been disputed by the Appellant Revenue that the transport activities have been performed within the mining area of TSL, then confirmation of demand on such activity by treating the same as mining service cannot be sustained. - The transport charges cannot be included in the valuation for mining services - AT....