High Court affirms CENVAT credit for deemed exports to 100% EOU, no substantial question of law

The High Court upheld the Tribunal's decision allowing CENVAT credit for input services used in manufacturing goods for export to a 100% EOU without physical export. Relying on legal precedents and the Apex Court's dismissal of Revenue's appeal, the court concluded that no substantial question of law arose, affirming the admissibility of CENVAT credit for deemed exports to a 100% EOU.

---

---

Issues:
Whether CENVAT credit is available for input services used in manufacturing goods for export to a 100% EOU without physical exportRs.

Analysis:

1. The appellant-Revenue appealed against a Tribunal order allowing appeals related to CENVAT credit availability for input services used in manufacturing goods for export to a 100% EOU without physical export.

2. The main issue raised was whether CENVAT credit is admissible for input services used in manufacturing goods for export to a 100% EOU without physical export. The Tribunal allowed the appeals based on the nexus of input services to the appellant's business activities.

3. The High Court of Gujarat's decision in a similar case supported the admissibility of CENVAT credit for deemed exports to a 100% EOU. The court referenced previous judgments to establish the legal position and dismissed the Revenue's appeal.

4. The High Court noted that the Revenue's appeal against the Gujarat High Court's decision was dismissed by the Apex Court, reinforcing the settled legal position on the admissibility of CENVAT credit for deemed exports to a 100% EOU.

5. Considering the legal precedents and the dismissal of the Revenue's appeal by the Apex Court, the High Court concluded that no substantial question of law arose for consideration. Therefore, the present appeals were dismissed based on the established legal position.

---