Cenvat credit on input services cannot be denied by relying on embedded goods precedents when the dispute concerns services.

Cenvat credit on input services used for a project was held allowable, because the dispute was governed by an earlier ruling recognising credit for input services. Authorities dealing with embedded goods, inputs or capital goods were found inapplicable, since the distinction between "input" and "input service" was material and decisive. The objection based on the pipeline being embedded to earth was therefore rejected, and the applicant was held entitled to credit only in respect of input services.

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Issues: Whether the applicant was entitled to Cenvat credit in respect of input services used for the project, and whether precedents concerning embedded goods or inputs applied to deny such credit.

Analysis: The ruling treated the controversy as covered by an earlier advance ruling that had already held that Cenvat credit is available in respect of input services. It distinguished the cited authorities dealing with inputs or goods embedded to earth, holding that those decisions did not govern a case concerning input services. The distinction between "input" and "input service" was treated as material and decisive.

Conclusion: The applicant was held entitled to Cenvat credit only in respect of input services, and the objection based on the embedded nature of the pipeline was rejected.

Ratio Decidendi: Where the dispute concerns input services, authorities dealing with embedded inputs or capital goods do not govern, and Cenvat credit on input services cannot be denied on that basis.

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