Container Rental in Liquidation Deemed Sale Under Article 366(29A)(d); Excluded from Service Tax Scope.

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....Nature of transaction - service or deemed sale - the company (in liquidation) had given the containers to the lessee on rental basis and possession and control was always with the lessee - appropriate VAT at the rate of 12.5% was paid by the company - it is a deemed sale within the meaning of Article 336(29A)(d) of the Constitution of India and outside the purview of Finance Act, 1994. (service tax) - HC....