Integrated input service principle allows full Cenvat credit on commission paid to a commission agent.

A commission agent's service was treated as one integrated input service under Rule 2(l) of the Cenvat Credit Rules, 2004, so it could not be artificially split into pre-clearance and post-clearance components. Because the service was not shown to fall outside the input service definition, full Cenvat credit on the commission paid was admissible.

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Issues: Whether Cenvat credit of service tax paid on commission paid to a commission agent for services rendered during the relevant period was admissible in full.

Analysis: The commission agent's activity was treated by the lower authorities as divisible into pre-clearance and post-clearance functions, and credit was denied for the latter. The service was held to be one integrated service incapable of such bifurcation. It was also noted that the service was not shown to fall outside Rule 2(l) of the Cenvat Credit Rules, 2004, and the decision in Bhilai Auxiliary Industries supported full credit on the commission paid.

Conclusion: Full Cenvat credit on the entire commission paid to the commission agent was admissible.

Ratio Decidendi: Where a commission agent's service is an integrated input service within Rule 2(l) of the Cenvat Credit Rules, 2004, the credit cannot be denied by artificially splitting the service into separate pre-clearance and post-clearance components.

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