Buyers of coal are liable for service tax on GTA services under reverse charge mechanism per Rule 2(1)(d) 21(v).

Liability of Service Tax on GTA service - Reverse Charge - Appellant being agent / intermediatory - SECL was the consignor and buyers of the coal were consignees and referring to large number of instances where the incidence of freight was actually borne by the consignees and which has not been disputed by the Revenue, it is the buyers of the coal who are liable to make the payment of service tax on freight amount paid to the transporter for transportation of coal in terms of Rule 2(1)(d) 21(v) of Service Tax Rules, 1994. - AT .....

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