Prospective amendment to input service definition preserved Cenvat credit on outward transportation before 01.04.2008.

Cenvat credit on service tax paid for outward transportation remained admissible for the period before 01.04.2008 because the amendment to the definition of input service operated prospectively. The pre-amendment phrase, which allowed credit up to the place of removal, continued to govern transactions before the change took effect, and the later restriction did not apply retrospectively. On that basis, credit on Goods Transport Agency service for the earlier period was treated as allowable, and the Revenue's challenge failed.

---

---

Issues: Whether Cenvat credit of service tax paid on outward transportation service was admissible for the period prior to 01.04.2008.

Analysis: The amended definition of input service, effective from 01.04.2008, substituted the expression "up to the place of removal" with "from the place of removal". The issue was treated as covered by the decisions of the High Courts holding that credit on Goods Transport Agency service prior to 01.04.2008 remained admissible and that the restriction applied only after the amendment date.

Conclusion: Credit of service tax on outward transportation service prior to 01.04.2008 was admissible, and the Revenue's challenge failed.

Final Conclusion: The appeal was rejected after holding that the pre-amendment entitlement to credit on outward transportation service continued until the amended definition took effect.

Ratio Decidendi: When the definition of input service is amended prospectively, credit admissibility is governed by the unamended definition for the period before the amendment takes effect.

---