Cenvat credit on event management service upheld where rectified invoices proved receipt by the assessee and promotion supported taxable output service.

Cenvat credit was held not to be deniable merely because event management invoices were first issued in the head office's name, where rectified invoices and a service-provider certificate showed that the service was actually rendered to the assessee and the initial billing was inadvertent. Event management service used to promote the assessee's advertisement space was also treated as an input service under Rule 2(l) of the Cenvat Credit Rules, 2004, because the assessee was engaged in taxable advertisement-space services and the record showed it as the recipient of the service. On that basis, the denial of credit was found unsustainable.

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Issues: (i) Whether Cenvat credit could be denied merely because the invoices for event management service were initially issued in the name of the head office, and (ii) whether event management service used for promotion of the assessee's advertisement space constituted an input service.

Issue (i): Whether Cenvat credit could be denied merely because the invoices for event management service were initially issued in the name of the head office.

Analysis: The assessee produced rectified invoices and a certificate from the service provider stating that the service was rendered to the assessee and that the original billing in the head office name was inadvertent. The Revenue did not rebut this evidence with contrary material.

Conclusion: Cenvat credit could not be denied on this ground, and the assessee was entitled to credit on the invoices so rectified and certified.

Issue (ii): Whether event management service used for promotion of the assessee's advertisement space constituted an input service.

Analysis: The record showed that the assessee was engaged in selling advertisement space and was paying service tax on that output service. The invoices also showed that the assessee was the recipient of the event management service. The contrary finding that the service was availed by clients was not supported by the record.

Conclusion: Event management service qualified as an input service for the assessee under Rule 2(l) of the Cenvat Credit Rules, 2004.

Final Conclusion: The denial of Cenvat credit was unsustainable and the assessee succeeded in full.

Ratio Decidendi: Cenvat credit cannot be denied where documentary evidence establishes that the assessee actually received the service, and a service used for promotion of the assessee's taxable output service falls within the scope of input service.

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