Appeal allowed: 6-month limitation doesn't apply to pre-01.09.2014 invoices. Verify invoice dates for compliance.

The Tribunal allowed the appeal, holding that the 6-month limitation period under Notification No. 21/2014-CE(NT) does not apply to invoices issued before 01.09.2014. Relying on established case law and judicial precedents, the Tribunal ruled in favor of the appellant, directing verification of invoice dates by the Adjudicating Authority to ensure compliance.

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Issues:
1. Denial of cenvat credit of invoices issued prior to 01.09.2014.
2. Applicability of Notification No. 21/2014-CE(NT) dated 11.07.2014.
3. Interpretation of the limitation period for availing cenvat credit.

Analysis:
1. The appeal was filed against the denial of cenvat credit for invoices issued before 01.09.2014, citing a lapse in the period for claiming credit. The central issue was the interpretation of Notification No. 21/2014-CE(NT) dated 11.07.2014, specifically the proviso added to Rule 4 of the Cenvat Credit Rules 2004. The Tribunal considered a similar case decided by the Hon'ble High Court of Delhi and a previous order passed in the appellant's case for a different unit. The Tribunal examined whether the cenvat credit availed after 01.09.2014 for invoices issued before that date was time-barred under the mentioned notification.

2. The Tribunal referred to the case law of Bharat Aluminium Company Ltd. v. Joint Commissioner of Central Excise, Central Tax Goods and Service Tax, where it was held that the 6-month limitation specified in Notification No. 21/2014-CE(NT) does not apply to invoices issued before 01.09.2014. This interpretation was supported by various decisions such as Indian Potash Ltd. v. Commissioner of Central GST, Hindustan Coca Cola Beverages Pvt. Ltd. v. Commissioner of Central Tax, and others. The Tribunal emphasized that the issue was settled in favor of the assessee based on the Delhi High Court judgment in the case of Global Ceramics Private Limited and others.

3. Consequently, the Tribunal allowed the appeal, relying on the precedent set by the Delhi High Court judgment and the established interpretation that the limitation period for claiming cenvat credit did not apply to invoices issued prior to 01.09.2014. The Tribunal directed the Original Adjudicating Authority to verify that the invoices in question indeed predated 01.09.2014, ensuring compliance with the decision. The decision was based on the settled law and clear judicial precedents, ultimately upholding the appellant's entitlement to the cenvat credit for the invoices issued before the specified date.

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