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    <title>2026 (8) TMI 790 - CESTAT CHENNAI</title>
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    <description>CENVAT credit exclusively attributable to trading activity was treated as inadmissible and subject to re-quantification under the prescribed trading formula, while proportionate credit for rented premises used to provide taxable services was considered admissible. The Members differed on whether the extended limitation period applied to reversal of trading-related credit: one view relied on the Supreme Court-approved position, while the other treated the issue as interpretational, with disclosed records and conflicting authorities precluding extended limitation and penalties. They also differed on the relevance of the doctrine of demurrer. The disputed questions were referred for resolution through a Third Member mechanism.</description>
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      <description>CENVAT credit exclusively attributable to trading activity was treated as inadmissible and subject to re-quantification under the prescribed trading formula, while proportionate credit for rented premises used to provide taxable services was considered admissible. The Members differed on whether the extended limitation period applied to reversal of trading-related credit: one view relied on the Supreme Court-approved position, while the other treated the issue as interpretational, with disclosed records and conflicting authorities precluding extended limitation and penalties. They also differed on the relevance of the doctrine of demurrer. The disputed questions were referred for resolution through a Third Member mechanism.</description>
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