Cenvat credit on input services and limitation objection require fresh appellate scrutiny where findings are incomplete.

Cenvat credit disputes on input services require a full examination of the eligibility of each disputed service and any limitation plea before final disposal. Where the appellate authority does not record findings on several input services specifically raised in the show cause notice, and the record shows that the assessee has produced return and credit documents, the matter cannot be conclusively decided on the available material. The impugned order was set aside and the case was remanded for fresh consideration of credit eligibility on the other input services and the limitation objection, with a reasonable opportunity of hearing.

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Issues: Whether the denial of cenvat credit on input services other than club or membership fees, and the objection on limitation, had been properly examined so as to sustain the impugned order.

Analysis: The demand covered multiple services, but the appellate authority had not returned findings on the eligibility of credit on several other input services specifically listed in the show cause notice. The record also showed that the appellant had raised limitation and had furnished details of monthly returns and credit documents. As the dispute required a deeper examination of the input service distributor invoices, the factual and legal issues could not be finally determined on the material before the Tribunal.

Conclusion: The impugned order was set aside and the matter was remanded to the Commissioner (Appeals) for fresh consideration of eligibility of credit on the other input services and the plea of limitation, after affording a reasonable opportunity of hearing.

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