The petitioner challenged the advance ruling and appellate advance ruling holding that the value of diesel supplied free of cost by the service recipient should be included in the taxable value of GTA services. The factual background showed that fuel was supplied by the recipient and did not form part of consideration.
The Court held that only consideration agreed between the parties can form part of taxable value under Section 15. Free diesel supplied by the recipient does not constitute consideration. The impugned advance rulings were set aside.