CENVAT credit on reverse charge tax for overseas agent services held admissible where activities matched business auxiliary services.

CENVAT credit was admissible on service tax paid under reverse charge for services received from overseas agents where the services, including sales promotion, handling, storage, assembly, logistics, quality services, repacking, warehousing and delivery, fell within the same taxing entry as business auxiliary services. The reasoning treated such services as materially similar to overseas commission agent services for credit purposes, and no valid basis was found to distinguish them. The Revenue's appeal therefore failed.

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Issues: Whether CENVAT credit was admissible on service tax paid under reverse charge on services received from overseas agents performing sales promotion, handling, storage, assembly, logistics, quality services, repacking, warehousing and delivery activities.

Analysis: Credit on tax paid under reverse charge for services of an overseas commission agent was already treated as permissible. The disputed services also fell within the same taxing entry covering business auxiliary services, and there was no sound basis to distinguish them from commission agent services for the purpose of allowing credit.

Conclusion: The credit was admissible and the Revenue's appeal failed.

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