Broad input service definition under Cenvat rules supports credit and refund for export-linked business services.

Rule 2(l) of the Cenvat Credit Rules, 2004 was read broadly to cover services used directly or indirectly in manufacture as well as services relating to business. Rent-a-cab, outdoor catering, air travel agent, telephone/mobile and steamer agent services were treated as business-related input services because they were connected with the assessee's manufacturing and export activity. The narrow view that only services directly tied to manufacture qualify was rejected, and the export-oriented character of the unit, together with the policy against exporting taxes, supported admissibility of Cenvat credit and refund under the export refund scheme.

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Issues: Whether service tax paid on rent-a-cab, outdoor catering, air travel agent, telephone/mobile and steamer agent services qualified as input service for Cenvat credit and refund under the export refund scheme.

Analysis: The definition of input service under rule 2(l) of the Cenvat Credit Rules, 2004 was construed as a wide, composite definition covering not only services used directly or indirectly in or in relation to manufacture and clearance up to the place of removal, but also services used in relation to activities relating to business. The expressions "means and includes", "such as", "business" and "relating to" were read as enlarging, not restricting, the scope of the definition. The services in question were treated as business-related services connected with the assessee's manufacturing activity and export business, and the Court rejected the narrow view that only services directly tied to manufacture would qualify. The export orientation of the unit and the policy against exporting taxes also supported admissibility of credit and refund.

Conclusion: The disputed services were held to be input services and the refund claims were admissible in favour of the assessee.

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