Input service coverage for outward freight before 1.4.2008 allowed CENVAT credit on GTA transportation to buyers' premises.

For periods before 1.4.2008, GTA service used to transport final products from the factory to buyers' premises was treated as input service under Rule 2(l) of the CENVAT Credit Rules, 2004, because the then-existing definition covered transportation from the place of removal. In light of the pre-amendment wording and the higher court view upholding that outward transportation fell within that expression, CENVAT credit was admissible. The denial of credit for the relevant period was therefore unsustainable.

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Issues: Whether CENVAT credit was admissible on GTA service used for outward transportation of final products to buyers' premises for the period prior to 1.4.2008.

Analysis: The definition of input service under Rule 2(l) of the CENVAT Credit Rules, 2004, as it stood before amendment on 1.4.2008, covered transportation from the place of removal. The dispute period being prior to that amendment, and the higher court having upheld the view that transportation from the factory to the buyers' premises fell within that expression, the assessee was entitled to the benefit.

Conclusion: CENVAT credit on the GTA service was admissible to the assessee for the relevant period, and the denial of credit was unsustainable.

Ratio Decidendi: For periods prior to 1.4.2008, outward transportation of final products from the factory to the buyers' premises falls within the scope of input service when covered by the expression from the place of removal.

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