Consignment notes by substance, not label, can bring individual truck owners' transport services within Goods Transport Agency taxation

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....Goods Transport Agency service under Section 65(50b) depends on road transport coupled with issuance of a consignment note, without distinguishing incorporated transporters from individual truck owners. The phrase "consignment note, by whatever name called" makes the document's substance, rather than its label, decisive. Pay slips containing vehicle details, goods description and quantity, origin and destination, and transporter acknowledgment may substantially satisfy that description. Where such documents evidence movement of goods, the transportation may fall within GTA service even if no document is formally titled a consignment note. Consequently, taxability follows and a refund claim for tax deposited during investigation may not be maintainable.....