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    <title>2017 (12) TMI 157 - CESTAT MUMBAI</title>
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    <description>The appeals were dismissed as the appellants, engaged in exporting non-excisable commodity &quot;fruits pulp,&quot; were deemed service receivers under the reverse charge mechanism. The original adjudicating authority rejected their refund claims for man power recruitment service and security service citing Cenvat Credit Rules and notifications, stating they were not entitled to refund or Cenvat Credit due to the non-excisable nature of their final products. The Commissioner (Appeals) affirmed this decision, emphasizing that the appellants, despite paying service tax, did not qualify as output service providers eligible for Cenvat Credit.</description>
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      <link>https://www.taxtmi.com/caselaws?id=351888</link>
      <description>The appeals were dismissed as the appellants, engaged in exporting non-excisable commodity &quot;fruits pulp,&quot; were deemed service receivers under the reverse charge mechanism. The original adjudicating authority rejected their refund claims for man power recruitment service and security service citing Cenvat Credit Rules and notifications, stating they were not entitled to refund or Cenvat Credit due to the non-excisable nature of their final products. The Commissioner (Appeals) affirmed this decision, emphasizing that the appellants, despite paying service tax, did not qualify as output service providers eligible for Cenvat Credit.</description>
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