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Issues: Whether the service availed for maintaining first-aid facilities and trained first-aid personnel, required under the Factories Act and the Mines Act, qualifies as an input service used in or in relation to the manufacture of final products, entitling the assessee to Cenvat credit.
Analysis: The maintenance of first-aid facilities for workers in the factory and mines was a statutory obligation under the Factories Act, 1948 and the Mines Act, 1952. Since compliance with those enactments was necessary for carrying on manufacturing activity, the service engaged for that purpose was not a remote welfare measure but a service connected with the business of manufacture. The definition of input service extends to services used directly or indirectly in or in relation to manufacture, and the reasoning adopted by the Gujarat High Court on statutorily mandated canteen services applied equally to first-aid services that are indispensable for running the factory.
Conclusion: The service was held to be an input service and the denial of Cenvat credit was unsustainable.