Housekeeping services qualify for Cenvat credit when factory cleanliness is a statutory necessity for manufacturing compliance.

Housekeeping services used to maintain cleanliness in factory premises were treated as input services eligible for Cenvat credit because compliance with the cleanliness requirement under the Factories Act was viewed as integral to manufacturing operations. On that basis, the denial of credit, together with interest and penalty, was found unsustainable on the housekeeping issue and set aside in favour of the assessee. The remaining appeals were not pressed and therefore did not survive for merits-based adjudication.

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Issues: Whether housekeeping services used for maintaining cleanliness of the factory premises are eligible input services for Cenvat credit, and whether the denial of credit and consequential interest and penalty on that count was sustainable.

Analysis: Housekeeping was found to be used for keeping the factory premises neat and clean, which was treated as a statutory requirement under Section 11 of the Factories Act, 1948. On that reasoning, such service was held to be used by the manufacturer in or in relation to manufacture, because manufacturing operations cannot be effectively carried on without compliance with the cleanliness requirement and the maintenance of a safe and efficient workplace.

Conclusion: Cenvat credit on housekeeping services was held admissible and the denial of credit, interest, and penalty on that issue was set aside in favour of the assessee.

Final Conclusion: The dispute on housekeeping services was decided for the assessee, while the remaining appeals were not pressed and did not survive for adjudication on merits.

Ratio Decidendi: Services used for maintaining factory cleanliness, where such cleanliness is a statutory and operational necessity for manufacturing, qualify as input services used in or in relation to manufacture for Cenvat credit purposes.

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