Cenvat credit on business-linked insurance services upheld, as retrospective denial through an allegedly clarificatory amendment was rejected.

Cenvat credit was held admissible on insurance services connected with manufacturing business, including plant and machinery insurance, marine insurance, employee group insurance, and insurance of vehicles, laptops, cash and other assets, because the input service definition was read broadly to cover services integrally connected with business operations. Employee group insurance was also treated as eligible where it related to statutory welfare obligations linked to manufacturing activity. The attempted retrospective denial of credit through an amendment was rejected because the deletion was not shown to be merely clarificatory, and the contrary view was found inconsistent with binding precedent and judicial discipline. The denial of credit was therefore unsustainable.

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Issues: (i) Whether Cenvat credit was admissible on insurance services such as plant and machinery insurance, marine insurance, employees group insurance, and insurance of vehicles, laptops, cash and other assets as input services; (ii) whether the amendment to the input service definition could be treated as clarificatory and applied retrospectively to deny such credit.

Issue (i): Whether Cenvat credit was admissible on insurance services such as plant and machinery insurance, marine insurance, employees group insurance, and insurance of vehicles, laptops, cash and other assets as input services.

Analysis: The definition of input service was construed broadly to include services used not only directly or indirectly in manufacture but also services integrally connected with the business of manufacturing. Insurance of plant and machinery, goods in transit, cash in transit, vehicles and laptops was treated as part of the manufacturing business because such protections are ordinarily necessary for carrying on manufacturing operations. Employees group insurance was also treated as eligible because compliance with statutory employee welfare requirements was part of the manufacturing business and the service had nexus with the business of manufacture.

Conclusion: Cenvat credit on the impugned insurance services was admissible.

Issue (ii): Whether the amendment to the input service definition could be treated as clarificatory and applied retrospectively to deny such credit.

Analysis: The retrospective application of the amendment was rejected because no adequate reasoning supported the view that the deletion of the relevant expression was merely clarificatory. The earlier binding decisions on similar insurance services were not properly distinguished, and the adjudication was found to be contrary to settled precedent and judicial discipline.

Conclusion: The amendment could not be applied retrospectively to deny credit in the present case.

Final Conclusion: The denial of Cenvat credit on the insurance services was unsustainable, and the assessee was entitled to relief.

Ratio Decidendi: Services integrally connected with the business of manufacture qualify as input services for Cenvat credit, and a retrospective denial of such credit cannot be based on an unsupported characterization of an amendment as clarificatory.

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