Cenvat credit on outward freight upheld for FOR sales where delivery obligations and risk remained with the seller.

Cenvat credit on outward transportation was admissible where goods were sold on FOR basis and the invoices were inclusive of freight and insurance, with no separate recovery from customers. On those facts, the place of removal was treated as the customer's doorstep or destination, so outward freight formed part of input service for the relevant period. The High Court noted that the Tribunal had applied the relevant Board circular and Supreme Court decisions, and found no substantial question of law arising from the challenged order. The issue was answered in favour of the assessee and against the Revenue, with credit on outward freight upheld.

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Issues: Whether Cenvat credit of service tax paid on outward transportation was admissible where goods were sold on FOR basis and freight, transit risk, and delivery obligations remained with the seller till delivery at the customer's doorstep.

Analysis: The Tribunal's findings showed that the invoices were inclusive of freight and insurance, no extra amount was charged from customers, and the goods were cleared on FOR basis. On those facts, the place of removal was treated as the customer's doorstep or destination, and outward transportation formed part of the input service for the relevant period. The High Court found that the Tribunal had relied on the applicable Board circular and the governing Supreme Court decisions, and that no substantial question of law arose from the order under challenge.

Conclusion: The issue was answered in favour of the assessee and against the Revenue; the Cenvat credit on outward freight was held admissible.

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