Input service includes vehicle-tracking used for inputs and finished goods, making Cenvat credit admissible.

Vehicle-tracking services used to monitor the movement of inputs to the factory and finished goods to customers fell within the inclusive scope of input service under Rule 2(l) of the Cenvat Credit Rules, 2004. The service was connected with the business of manufacture and procurement of inputs, and it was not excluded merely because part of the use occurred after clearance from the factory. Cenvat credit was therefore admissible, the denial of credit was unsustainable, and the impugned order was set aside.

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Issues: Whether vehicle-tracking services used for monitoring movement of inputs and finished goods qualify as input service under Rule 2(l) of the Cenvat Credit Rules, 2004 so as to allow Cenvat credit.

Analysis: The definition of input service for a manufacturer contains both a substantive limb covering services used directly or indirectly in or in relation to manufacture and clearance of final products, and an inclusive limb extending to services connected with the business of manufacture. On the facts, the tracking service was used not only for monitoring finished goods till delivery but also for tracking inputs coming to the factory. Such service fell within the broader inclusive part of the definition, including activities relating to business and procurement of inputs. The service was not excluded merely because some use occurred after clearance from the factory.

Conclusion: The service qualified as input service and Cenvat credit was admissible; the denial of credit was unsustainable.

Final Conclusion: The impugned order was set aside and the appeal succeeded.

Ratio Decidendi: A service used for tracking movement of inputs and finished goods in connection with the manufacturing business, including post-manufacture delivery functions, falls within the inclusive scope of input service under Rule 2(l) of the Cenvat Credit Rules, 2004.

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