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Issues: Whether Cenvat credit is admissible on commission paid to agents for sales promotion through sale of dutiable goods on commission basis.
Analysis: Sales promotion includes services rendered for sale of dutiable goods on a commission basis within the definition of input service. The Board clarification allowing such credit was confirmed by the subsequently inserted Explanation to Rule 2(l), which was treated as declaratory and retrospectively effective for resolving divergent judicial views.
Conclusion: Cenvat credit on sales commission paid to agents for sales promotion is admissible; the issue is decided in favour of the assessee.