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    <title>2025 (1) TMI 72 - CESTAT ALLAHABAD</title>
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    <description>In refund proceedings under Rule 5, admissibility of CENVAT credit cannot be reopened for the first time where no prior proceedings were initiated under Rule 14 read with Section 73 to reverse or recover the credit. The refund framework is confined to verification of export of services and availability of credit, not a fresh adjudication on the correctness of credit already availed. Refund of accumulated CENVAT credit also cannot be denied for want of one-to-one correlation between input services and exported output services, or for absence of invoices from a foreign service provider, where tax was discharged under reverse charge and the supporting challans were accepted. The refund claim was therefore maintainable and consequential relief followed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=764010</link>
      <description>In refund proceedings under Rule 5, admissibility of CENVAT credit cannot be reopened for the first time where no prior proceedings were initiated under Rule 14 read with Section 73 to reverse or recover the credit. The refund framework is confined to verification of export of services and availability of credit, not a fresh adjudication on the correctness of credit already availed. Refund of accumulated CENVAT credit also cannot be denied for want of one-to-one correlation between input services and exported output services, or for absence of invoices from a foreign service provider, where tax was discharged under reverse charge and the supporting challans were accepted. The refund claim was therefore maintainable and consequential relief followed.</description>
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