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    <title>2026 (6) TMI 765 - CESTAT HYDERABAD</title>
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    <description>CENVAT credit on leadership fee distributed through the ISD mechanism could not be denied at the recipient end on a mere procedural objection where service tax payment, receipt of service, and distribution of credit were undisputed. In a composite turnkey consortium project, the leadership fee was linked to overall coordination and execution of the integrated arrangement, so it could not be selectively dissected and attributed only to exempt activity. The note also records that Consulting Engineer Service fell within Rule 6(5) of the CENVAT Credit Rules, 2004, entitling the assessee to full credit absent proof of exclusive use in exempted goods or services, with demand, interest, and penalty failing as consequentially unsustainable.</description>
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      <description>CENVAT credit on leadership fee distributed through the ISD mechanism could not be denied at the recipient end on a mere procedural objection where service tax payment, receipt of service, and distribution of credit were undisputed. In a composite turnkey consortium project, the leadership fee was linked to overall coordination and execution of the integrated arrangement, so it could not be selectively dissected and attributed only to exempt activity. The note also records that Consulting Engineer Service fell within Rule 6(5) of the CENVAT Credit Rules, 2004, entitling the assessee to full credit absent proof of exclusive use in exempted goods or services, with demand, interest, and penalty failing as consequentially unsustainable.</description>
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