Cenvat credit on CHA services requires documentary nexus with imported inputs; a certificate alone is not enough.

Cenvat credit on CHA services used for import of inputs is available only where the assessee proves a clear documentary nexus between the services and the manufacturing or procurement of inputs. The broad definition of input service was not enough by itself; the services had to be correlated with specific bills of entry for clearance of inputs. A Chartered Accountant's certificate alone was treated as insufficient proof of such linkage. On that basis, the credit on CHA services was held inadmissible and the order denying credit was sustained for want of reliable documentary correlation.

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Issues: Whether service tax paid on CHA services availed for import of inputs was admissible as Cenvat credit.

Analysis: The definition of input service under Rule 2(1) of the Cenvat Credit Rules, 1994 was treated as broad, but credit could be allowed only when the assessee established that the CHA services were used in relation to manufacturing activity and were correlated with specific bills of entry relating to clearance of inputs. In the absence of such correlation, a Chartered Accountant's certificate by itself was not considered sufficient proof for grant of credit.

Conclusion: The credit was held inadmissible and the appeal failed.

Final Conclusion: The order denying Cenvat credit on CHA services was sustained for want of documentary nexus with imported inputs.

Ratio Decidendi: Cenvat credit on input services is admissible only when the assessee proves, through reliable documentary correlation, that the services were used in relation to manufacture or procurement of inputs; a bare certificate is insufficient.

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