Appeal allowed on limitation ground, with relief. Cenvat credit denied for outdoor catering post-2011.

The appeal was allowed on the ground of limitation, with consequential relief, based on the interpretational nature of the issue and conflicting tribunal decisions. The appellant's eligibility for cenvat credit on outdoor catering services was denied following the Wipro Ltd. case, which deemed such credit ineligible post-2011 due to exclusion clauses.

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Issues Involved:
Whether the appellants are eligible to avail cenvat credit on outdoor catering services for the period from March 2016 to June 2017.

Analysis:

Issue 1: Eligibility of cenvat credit on outdoor catering services
The appellant, engaged in manufacturing, provided canteen facilities to employees through third-party caterers. The Department contended that cenvat credit on outdoor catering services was not eligible due to an amendment in Rule 2(l) of CCR 2004. The appellant argued that the services were integral to manufacturing as per statutory requirements and relied on precedents like Hindustan Coca Cola Beverages Pvt. Ltd. and Roca Bathroom Products Pvt. Ltd. The appellant also highlighted the compliance with the Factories Act and Rules. The Department relied on the Wipro Ltd. case, where post-2011 credit on outdoor catering services was deemed ineligible. The Tribunal upheld this view, citing legislative intent and exclusion clauses. The appellant's argument on limitation was accepted, considering conflicting tribunal decisions and the interpretational nature of the issue. The demand was deemed time-barred, and the impugned order was set aside on this ground.

Conclusion:
The appeal was allowed on the ground of limitation, with consequential relief, based on the interpretational nature of the issue and conflicting tribunal decisions. The appellant's eligibility for cenvat credit on outdoor catering services was denied following the Wipro Ltd. case, which deemed such credit ineligible post-2011 due to exclusion clauses.

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