FOR sales and freight-in-value support Cenvat credit on outward GTA services as eligible input service.

Cenvat credit on outward GTA services was treated as admissible where goods were sold on FOR basis, freight was borne by the seller up to the customer's doorstep, and the freight element formed part of the assessable value on which excise duty was paid. On those facts, the place of removal was taken to be the customer's end, making destination freight an eligible input service. The analysis also relied on earlier Tribunal views in similar factual settings and on the principle that seller-retained ownership and risk until delivery support credit eligibility for outward transportation.

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Issues: Whether Cenvat credit on GTA services used for outward freight was admissible where the sales were on FOR basis and freight formed part of the assessable value.

Analysis: The facts were not in dispute. The goods were sold on FOR basis, freight was borne by the appellant up to the customer's doorstep, and the freight element was included in the assessable value on which excise duty had been discharged. On these facts, the place of removal followed the point of sale at the customer's end, and the outward freight fell within the eligible input service. The decision was supported by the Tribunal's earlier view in identical factual settings and by the principle that ownership and risk remaining with the seller till delivery supports treatment of destination freight as creditable. The benefit of the relevant circulars was also treated as available for the material period.

Conclusion: Cenvat credit on outward GTA service was admissible to the appellant.

Final Conclusion: The impugned order was set aside and the appeal was allowed on the central issue of credit eligibility for FOR sales.

Ratio Decidendi: Where goods are sold on FOR basis and freight is included in the assessable value, outward transportation up to the customer's doorstep is integrally connected with the sale and qualifies for credit as input service.

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