CENVAT credit allowed before registration and on employee meal coupons under the broader pre-2011 input service definition.

CENVAT credit was held admissible even if availed before service tax registration, because the CENVAT Credit Rules did not make prior registration a condition for credit and earlier authority supported that view. Credit on meal coupons provided to employees was also allowed, as the relevant period preceded 01.04.2011 when the definition of input service was broader and employee food benefits were treated similarly to outdoor catering or canteen facilities. The disallowance was set aside and input credit was upheld with consequential relief.

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Issues: (i) whether CENVAT credit availed before taking service tax registration was admissible; (ii) whether credit on meal coupons provided to employees was admissible as input service credit.

Issue (i): whether CENVAT credit availed before taking service tax registration was admissible.

Analysis: The Tribunal held that the CENVAT Credit Rules do not require prior registration as a condition for availing credit. The view was supported by earlier judicial authority holding that credit cannot be denied merely because it was taken before registration.

Conclusion: Credit availed prior to taking registration was held admissible and the issue was decided in favour of the assessee.

Issue (ii): whether credit on meal coupons provided to employees was admissible as input service credit.

Analysis: The Tribunal noted that the relevant period was before 01.04.2011 when the definition of input service had a wide ambit. Meal coupons were treated as a form of employee food benefit comparable to outdoor catering or canteen facilities, for which credit had been recognised as eligible.

Conclusion: Credit on meal coupons was held admissible and the issue was decided in favour of the assessee.

Final Conclusion: The disallowance of credit was set aside and the assessee's entitlement to input credit was upheld, with consequential relief.

Ratio Decidendi: Prior registration is not a prerequisite for availing CENVAT credit, and employee meal benefits falling within the broad pre-01.04.2011 understanding of input services can qualify for credit.

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