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Input Service Distributor (ISD) - Entitlement to Cenvat credit on the entire credit distributed by their head office despite the fact that the appellant company having three units - Rule 7 before 2012 allowed the ISD discretion to distribute the credit among its units without a mandatory proportional distribution. This rule changed post-2012 to require proportional distribution based on turnover, which was not the case during the period in question. - The tribunal noted several precedents where similar distributions of Cenvat credit were upheld under the unamended rules. - The tribunal agreed with the appellant that the show cause notices on jurisdictional grounds were inappropriate and that claims regarding the extended period were time-barred due to the absence of any factual suppression or misrepresentation by the appellant.
Input Service Distributor (ISD) - Entitlement to Cenvat credit on the entire credit distributed by their head office despite the fact that the appellant company having three units - Rule 7 before 2012 allowed the ISD discretion to distribute the credit among its units without a mandatory proportional distribution. This rule changed post-2012 to require proportional distribution based on turnover, which was not the case during the period in question. - The tribunal noted several precedents where similar distributions of Cenvat credit were upheld under the unamended rules. - The tribunal agreed with the appellant that the show cause notices on jurisdictional grounds were inappropriate and that claims regarding the extended period were time-barred due to the absence of any factual suppression or misrepresentation by the appellant.
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