Corporate restructuring services were held outside input service scope, so Cenvat credit was not admissible.

Professional services used for advising on group realignment and implementation of a proposed merger were treated as corporate restructuring services, with no nexus to manufacture or clearance of final products. They were also found not to fall within the inclusive categories of input services such as accounting, financing or legal services. On that basis, the services were held to be outside the scope of input service under the Cenvat Credit Rules, and Cenvat credit was not admissible.

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Issues: Whether services availed for corporate restructuring and merger were eligible as input services for Cenvat credit under Rule 2(i) of the Cenvat Credit Rules, 2004.

Analysis: The credit was claimed in respect of professional services used for advising on realignment of group structure and implementation of a proposed merger. The services were held to relate to corporate restructuring and not to have any nexus with manufacture or clearance of final products. They were also found not to fall within the inclusive heads of input services such as accounting, financing or legal services. On that basis, the services were treated as outside the scope of input service.

Conclusion: The services were not input services and Cenvat credit was not admissible.

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