Cenvat credit on security and manpower supply services upheld where both had nexus with manufacture of final products.

Cenvat credit was held admissible on security service and manpower recruitment supply service because both were treated as input services with nexus to manufacture of the final product. Security service was regarded as a business-related service, while manpower recruitment supply service was found directly connected with manufacturing activity in the factory. The concurrent factual findings below recorded that the services had the necessary nexus with manufacture, and no infirmity was found in those findings. The order allowing cenvat credit was therefore upheld and the Revenue's challenge failed.

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Issues: Whether cenvat credit was admissible on security service and manpower recruitment supply service as input services having nexus with the manufacture of the final product.

Analysis: The disputed services were found to fall within the scope of input service, with security service treated as a business-related service and manpower recruitment supply service treated as directly connected with manufacturing activity in the factory. The concurrent findings of the lower authority and the Commissioner (Appeals) recorded that the services had nexus with manufacture of the final product. No infirmity was found in those findings.

Conclusion: The disputed services were eligible for cenvat credit and the Revenue's challenge failed.

Final Conclusion: The order allowing cenvat credit was upheld and the Revenue appeal was rejected.

Ratio Decidendi: Services used in relation to business and those having a direct nexus with manufacture qualify as input services for cenvat credit.

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