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Issues: Whether credit of service tax on the disputed services was admissible as input service credit under the CENVAT Credit Rules, and whether the appellate authority had recorded service-wise findings sufficient to sustain allowance of credit.
Analysis: The dispute concerned ten specified services on which credit had been denied for alleged lack of nexus with the manufacturing activity. The appellate authority had relied on the inclusive definition of input service and on precedent, but had not dealt individually with each disputed service or explained how each service satisfied the requirements of the rule. In matters of input service credit, the decision must show how each claimed service falls within the statutory definition and the relevant nexus with business activity.
Conclusion: The allowance of credit could not be sustained on the existing reasoning, and the matter required fresh service-wise examination by the appellate authority.
Final Conclusion: The order granting credit was set aside and the dispute was sent back for reconsideration after a fresh, reasoned examination of each contested service.
Ratio Decidendi: When input service credit is claimed on multiple disputed services, the authority must record specific findings for each service on how it satisfies the statutory definition and nexus requirement before allowing the credit.