service
tax). Learned counsel for the appellants submits that as per section
65(50b) , goods transport agency is any person who provides service
in relation ... have considered the submissions. Charging sections of
taxing statutes must be strictly interpreted. Section 65(50b) clearly
defines goods transport agency as one who renders
taxable under Section 65(105)(zr) of the Act and the latter is
defined under Section 65(50b) of the Act which is taxable under ... Section 65(105)(zzp) of the Act. Both are reproduced as follows:
"65(23)- 'cargo handling service' means loading, unloading,
packing
providing "transport of goods by
road" service specified in section 65 (50b) of the Finance Act,
2
1994 1. The Department believed that ... appellant would be covered "cargo handling service" as
defined in section 65(23) of the Finance Act. Accordingly, a show
cause notice dated
fact it had
not issued any consignment note, as required under section 65
(50b) according to which Goods Transport Agency means "any
person
