https://www.taxtmi.com/caselaws?id=771480 A ratio drawn from one statutory regime cannot be applied mechanically to another unless the relevant provisions are first compared and found to be pari materia. The order notes that denial of Cenvat credit under Rule 2(l) of the Cenvat Credit Rules, 2004 had been based on direct reliance on the Safari Retreats principle from the GST regime and the Finance Act, 1994. It states that the Commissioner was required to compare Rule 2(l) with Section 17(5)(d) of the CGST Act, 2017 before reaching any conclusion. The matter was remanded for fresh consideration after that comparison, with liberty to make further submissions. en-us Tue, 06 May 2025 00:00:00 +0530 Tue, 27 May 2025 08:32:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771480 A ratio drawn from one statutory regime cannot be applied mechanically to another unless the relevant provisions are first compared and found to be pari materia. The order notes that denial of Cenvat credit under Rule 2(l) of the Cenvat Credit Rules, 2004 had been based on direct reliance on the Safari Retreats principle from the GST regime and the Finance Act, 1994. It states that the Commissioner was required to compare Rule 2(l) with Section 17(5)(d) of the CGST Act, 2017 before reaching any conclusion. The matter was remanded for fresh consideration after that comparison, with liberty to make further submissions. Case-Laws Central Excise Tue, 06 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771480