Cenvat credit on export delivery transport was upheld where DDP terms extended removal up to the buyer's premises.

Cenvat credit on courier and transportation services was allowed for exported goods delivered on Delivered Duty Paid terms because the place of removal was treated as extending to the foreign buyer's premises. The seller retained ownership and bore cost and risk until delivery, so the transport services up to destination formed part of the export transaction. The authority relied on by the Revenue was held inapplicable on these facts, while the earlier precedent supporting credit on transport to the buyer's doorstep was found satisfied. Credit was therefore admissible, and the Revenue's appeal was dismissed.

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Issues: Whether Cenvat credit was admissible on courier and transportation services used for delivery of exported goods to the foreign buyer's premises where the goods were sold on Delivered Duty Paid basis and the seller retained ownership till delivery.

Analysis: The appeal turned on whether the place of removal in an export transaction extended beyond the port of export. The circular relied on by the Revenue was held inapplicable because the sale was on Delivered Duty Paid terms, under which the seller bore the costs and risks up to destination and retained ownership of the goods till delivery. The conditions recognised in the earlier authority for allowing credit on transportation to the buyer's doorstep were found to be satisfied, and the contrary authority cited by the Revenue was distinguished on facts.

Conclusion: Cenvat credit on courier and transportation charges was admissible, and the Revenue's appeal was dismissed.

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