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of <h1>Manpower Recruitment Service qualifies as input service under CENVAT Credit Rules; credit admissible even if not directly used in manufacture</h1> CESTAT Ahmedabad held that Manpower Recruitment and Supply Service qualifies as an input service under the CENVAT Credit rules since it is used in ... CENVAT Credit - input services or not - Manpower Recruitment and Supply Service - HELD THAT:- The fact is not under dispute that the Manpower Service was used in overall activity of manufacturing and related activities. The Manpower Recruitment Service is also covered in the inclusion clause of the definition, therefore, even by stretch of imagination, it found that Manpower Supply Service is not directly used in the manufacture, even then in terms of the Recruitment Service covered under inclusion clause, credit is otherwise admissible. Therefore, there is no doubt that the ‘Manpower Recruitment and Supply Service’ being covered under inclusion clause is an admissible inputs service. The impugned order is set aside. The appeal is allowed. The Appellate Tribunal (CESTAT Ahmedabad) addressed whether the appellant is entitled to input tax credit for 'Manpower Recruitment and Supply Service.' The appellant contended that such services qualify as 'inputs service' since they are used in activities related to manufacturing the final product and fall under the 'inclusion clause' of the inputs service definition. Reliance was placed on precedents including *Wipro Ltd. v. Commissioner of C.Ex.*, 2018 (10) G.S.T.L. 172 (Mad.), and others. The Revenue upheld the impugned order denying credit. The Tribunal found the facts undisputed that the manpower services were used in manufacturing-related activities and that 'Manpower Recruitment Service' is explicitly covered under the inclusion clause. The Tribunal held that 'even by stretch of imagination' if manpower supply is not directly used in manufacture, credit remains admissible due to the recruitment service inclusion. The Tribunal concluded that the 'Manpower Recruitment and Supply Service' constitutes an admissible inputs service and set aside the impugned order, allowing the appeal.
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