Cenvat credit restriction: CVD paid on capital goods used for exempt services remains non claimable even after later taxation. Cenvat credit of CVD on capital goods used exclusively for exempted services at the time of import is not allowable; credit that was ab initio ineligible does not become eligible when the activity is later made taxable, and expressly including such goods within the definition of capital goods will not permit recovery of past ineligible CVD credit.