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    <title>2026 (4) TMI 1737 - CESTAT BANGALORE</title>
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    <description>Trading was treated as an exempted service retrospectively under Rule 6 of the Cenvat Credit Rules, 2004, following the amendment to Rule 2(e), so common input service credit linked to trading became subject to reversal requirements for the relevant period. Where the assessee had already reversed the entire common input service credit for financial year 2011-12 with interest, no further demand survived for that year because the reversal was treated as equivalent to non-availment. For the remaining period, the demand was time-barred because the Department already knew the trading activity and credit position from audit and statutory returns, and extended limitation was not available.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790668</link>
      <description>Trading was treated as an exempted service retrospectively under Rule 6 of the Cenvat Credit Rules, 2004, following the amendment to Rule 2(e), so common input service credit linked to trading became subject to reversal requirements for the relevant period. Where the assessee had already reversed the entire common input service credit for financial year 2011-12 with interest, no further demand survived for that year because the reversal was treated as equivalent to non-availment. For the remaining period, the demand was time-barred because the Department already knew the trading activity and credit position from audit and statutory returns, and extended limitation was not available.</description>
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