https://www.taxtmi.com/caselaws?id=465850 CENVAT credit on common input services attributable to trading was held inadmissible because trading is neither a taxable service nor an activity of manufacture; therefore, proportionate reversal was legally required even for periods prior to 01.04.2009. Finding the assessee's departmental intimations misleading and inconsistent, and noting absence of evidence of bona fide belief, the Tribunal held that suppression was established and the extended period of limitation was invocable for 2006-07 and 2007-08; consequently, recovery of proportionate credit for the pre-01.04.2009 period was upheld. For 2009-10 and 2010-11, once audit had detected the issue and reversal commenced, extended limitation was held inapplicable; recovery, if any, had to be within the normal period. Demand with interest was sustained. en-us Wed, 16 Aug 2023 00:00:00 +0530 Fri, 09 Jan 2026 18:21:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465850 CENVAT credit on common input services attributable to trading was held inadmissible because trading is neither a taxable service nor an activity of manufacture; therefore, proportionate reversal was legally required even for periods prior to 01.04.2009. Finding the assessee's departmental intimations misleading and inconsistent, and noting absence of evidence of bona fide belief, the Tribunal held that suppression was established and the extended period of limitation was invocable for 2006-07 and 2007-08; consequently, recovery of proportionate credit for the pre-01.04.2009 period was upheld. For 2009-10 and 2010-11, once audit had detected the issue and reversal commenced, extended limitation was held inapplicable; recovery, if any, had to be within the normal period. Demand with interest was sustained. Case-Laws Central Excise Wed, 16 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465850