CENVAT credit on garden maintenance denied where the service had only a remote nexus with manufacture.

Garden maintenance services were held not to qualify as input services for CENVAT credit because the expression requires a real and proximate nexus with manufacture, and cannot extend to every business expense. The connection between garden maintenance and the manufacture of pumps was found to be only remote, even though the activity was claimed to relate to pollution-control requirements or general business expenditure. Authorities cited by the appellant were distinguished on facts, while the Revenue's reasoning was accepted. Credit was therefore disallowed and the denial of CENVAT credit on garden maintenance services was sustained.

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Issues: Whether services used for maintenance of gardens are eligible as input services for CENVAT credit.

Analysis: The expression "input services" requires a nexus with the manufacture of final products and cannot be stretched to cover every expense incurred by a business. Maintenance of gardens, even if asserted to be required under pollution-control requirements or treated as part of business expenditure, was found to have only a remote connection with the manufacture of pumps. The authorities relied on by the appellant were distinguished on facts, while the reasoning in the decision relied on by the Revenue was found applicable.

Conclusion: Garden maintenance services are not input services for the purpose of CENVAT credit, and the disallowance of credit was upheld.

Final Conclusion: The appeal failed and the order denying CENVAT credit on garden maintenance services was sustained.

Ratio Decidendi: For CENVAT credit, a service must bear a real and proximate nexus with manufacture or business activity in relation to manufacture; a merely remote or incidental connection is insufficient.

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