Tribunal overturns credit denial for input services, citing lack of centralized billing system.

The Tribunal ruled in favor of the appellant, setting aside the order disallowing credit on various input services and citing the lack of a centralized billing system. The denial of credit on these grounds was deemed unjustified, and the show cause notice invoking the extended period due to alleged suppression of facts was found unsustainable. The appeal was allowed with consequential relief, if any, granted to the appellant.

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Issues:
1. Eligibility of credit on various input services.
2. Centralized billing system and credit availed on services utilized in other service centers.
3. Grounds of limitation for the show cause notice.

Eligibility of Credit on Various Input Services:
The appellant, engaged in maintenance and repair services, availed credit on input services like Mandap Keeper Service, Real Estate Agent Service, Transport of Goods by Air Service, and others. The appellant argued that any activity related to its business is eligible for credit, citing the definition of input services prior to 1.4.2011. Referring to a High Court judgment, it was held that denial of credit on the basis that these services do not qualify as input services is unjustified.

Centralized Billing System and Credit Availed on Services Utilized in Other Service Centers:
The appellant, despite having centralized registration without a centralized billing system, maintained that it had a centralized billing system and was availing credit on services used in other service centers at Hosur. It was noted that during the relevant period, there was no provision for Input Service Distributor (ISD) registration. The Tribunal held that denial of credit on this ground was unsustainable, especially since the department had accepted a precedent where credit was allowed even if services were utilized in different units of the appellant.

Grounds of Limitation for the Show Cause Notice:
The appellant argued on the ground of limitation, stating that necessary details of credit availed were furnished along with ST 3 returns, and the department had acknowledged these details. It was concluded that the show cause notice invoking the extended period alleging suppression of facts was not sustainable. The Tribunal ruled in favor of the appellant on the ground of limitation as well.

In conclusion, the impugned order disallowing credit on various input services and citing lack of centralized billing system was set aside both on merits and limitation grounds. The appeal was allowed with consequential relief, if any.

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