Export-related services qualify as input services up to the place of removal, allowing Cenvat credit on export operations.

Cenvat credit was held admissible on export-related services, including CFS dock expenses, C&F agent service, THC charges, outward freight and banking services, where the services were used in connection with goods exported from the factory. The analysis treated the export chain as continuing until delivery at the foreign port, so services used up to that stage were regarded as used up to the place of removal. Reliance was placed on the Board circular supporting that approach. On that basis, services used in the course of export up to the port of export qualified as input services, and credit was allowable.

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Issues: Whether Cenvat credit was admissible on export-related services such as CFS dock expenses, C&F agent service, THC charges, outward freight and banking services used in connection with goods exported from the factory.

Analysis: The services in question were used for export of goods cleared from the factory. In export transactions, ownership of the goods continues with the exporter until delivery at the foreign port, and services used up to that stage are treated as used up to the place of removal. The Board circular relied upon supported this position, and the services were found to have been used in the course of export before the foreign port of delivery. The Tribunal therefore accepted that the place of removal extended to the port of export for these transactions.

Conclusion: Cenvat credit on the disputed export-related services was admissible, and the denial of credit was unsustainable.

Final Conclusion: The impugned order was set aside and the appeal was allowed.

Ratio Decidendi: Where goods are exported and the services are used in relation to export operations up to the port of export, such services are treated as input services used up to the place of removal and credit is allowable.

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