𝗖𝗘𝗦𝗧𝗔𝗧 𝗔𝗵𝗺𝗲𝗱𝗮𝗯𝗮𝗱 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗚𝗼𝗼𝗱𝘀 𝗧𝗿𝗮𝗻𝘀𝗽𝗼𝗿𝘁 𝗔𝗴𝗲𝗻𝗰𝘆 (𝗚𝗧𝗔) 𝗧𝗮𝘅 𝗟𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝘆 📢 T𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗵𝗲𝗹𝗱: "Service tax is not applicable to the appellant, as it did not issue consignment notes for the transportation services provided, and such activities fall under the Negative List."

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: Chartered Logistics Limited. 𝗜𝘀𝘀𝘂𝗲: Whether the appellant is liable to pay service tax under GTA. 𝗦𝗲𝗿𝘃𝗶𝗰𝗲: The appellant provided transportation services to M/s FCPL and M/s Reliance Supply Chain Solution Ltd. without issuing consignment notes, which were instead issued by M/s FCPL.

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The Tribunal ruled that service tax is not applicable to the appellant since no consignment notes were issued, placing the service under the "Negative List" (Section 66D). M/s FCPL, the actual GTA, holds any tax liability, if due, for M/s Reliance Industries. Extended limitation was deemed inapplicable.

𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼: 𝗧𝗶𝘁𝗹𝗲: Chartered Logistics Limited vs. C.C.E - Ahmedabad-II 𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 𝗔𝗽𝗽𝗲𝗮𝗹 𝗡𝗼. 10857 of 2022- DB 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 19 July 2023 📜 𝗥𝘂𝗹𝗶𝗻𝗴: The Tribunal set aside the demand, ruling in favor of the appellant. The appeal was allowed.