Cenvat credit on input services requires payment first and documentary proof, with fresh verification needed before admissibility is accepted.

Cenvat credit on input services is available only on or after payment of the service value and service tax under Rule 4(7) of the Cenvat Credit Rules, 2004, and eligibility must be supported by documentary evidence under Rule 9(6). Sample verification showed that credit had been taken and utilised before tax payment in some cases, so the record required complete verification of all relevant documents before admissibility could be determined. The impugned order could not sustain the credit claim and the matter required fresh verification.

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Issues: Whether Cenvat credit on input services could be taken before payment of the value of input service and service tax, and whether the assessee had to establish eligibility through documentary evidence.

Analysis: Credit on input services is permissible only on or after the date on which payment of the value of the service and the service tax is made, in accordance with Rule 4(7) of the Cenvat Credit Rules, 2004. The assessee is required to substantiate eligibility by documentary proof under Rule 9(6). On verification of sample entries, credit had been availed and even utilised before tax was paid in some instances. The record therefore required a complete verification of all relevant documents before a final decision could be taken on the admissibility of credit.

Conclusion: The credit issue required fresh verification and could not be sustained on the basis of the impugned order.

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